G.R. No. 87429 - People vs. Bati

On June 6, 1959, CHUA ENG HOK filed a petition for naturalization with the Court of First Instance of Manila.
The petitioner claimed Filipino citizenship on the basis of his long residence in Manila and his adherence to the principles of the Constitution of the Philippines.
The petition included detailed personal information:

Residence: Current residence at 1764 Sisa St., Sampaloc, Manila; previous residences included 1327 Sanchez Ext., Tondo, Manila; San Pablo City, Laguna; and Libmanan, Camarines Sur.
Birth and Nationality: Born on March 14, 1925, in Chuansio, Chinkiang, China, and still recognized as a subject of the Republic of China.
Marital Status: Married to Osmundita Avila Palomar, a Filipino citizen born in Libmanan, Camarines Sur, with whom he resided at 1764 Sisa St., Sampaloc, Manila.
Children: Initially had three children at the time of filing the petition; the number had increased to four.
Income: Claimed an annual income of P4,000.00 through his employment at the Central Manufacturing Corporation.

The petitioner declared his belief in the principles underlying the Philippine Constitution and asserted that he had conducted himself in a proper and irreproachable manner.

The petitioner’s case was heard, during which he and his character witnesses testified regarding his residence, family, income, and moral character.
On May 3, 1960, the Court of First Instance of Manila granted the petition and ordered the issuance of a certificate of naturalization, contingent upon the petitioner’s compliance with the requirements set forth in the Naturalization Law (Commonwealth Act No. 473, as amended by Republic Act No. 530).

Under the Naturalization Law, a decision in a naturalization case does not become final and executory until after a two-year period.
On October 12, 1962, the Republic of the Philippines filed a petition objecting to the petitioner taking the oath of citizenship, seeking to nullify the decision rendered on May 3, 1960.
The grounds for the government’s objection included:

The petitioner allegedly did not state all of his former places of residence.
The notice of hearing was published in the "Daily Record," a newspaper not considered to be of general circulation in the Philippines.
The petitioner’s annual income of P4,000.00 was deemed insufficient, given that he was supporting a wife and four children, and thus not constituting a “lucrative trade or occupation” within the meaning of the naturalization law.

The government’s petition was denied on the same day it was filed, prompting the Solicitor General to take the case on appeal.

The court referenced several cases which dealt with the income requirement for naturalization, including:

Uy vs. Republic of the Philippines (L-19578): P4,200 annually with wife and three children below school age.
Yap Bun Pin vs. Republic (L-19577): P8,067.24 annually, with wife and five children.
Tio Tee Chai vs. Republic (L-19112): P5,000 annually, with wife and three children.
Go Bon The vs. Republic (L-16813): P7,133.29 annually, with wife and four children.
Uy Ching Ho vs. Republic (L-19582): P7,799.34 annually, with wife and five children.
Yu Kian Chie vs. Republic (L-20169): P400 per month, with a wife.
Uy Tian vs. Republic (L-19918): P7,000 annually, with wife and eight children.
Ong So vs. Republic (L-20145): P4,800 annually, including benefits of free board and lodging (valued at P150 to P200 per month), with wife and five children.
Chiu Bok vs. Republic (L-19111): P5,000 annually, with wife and five children.
Tan Kong Kiat vs. Republic (L-19915): P5,000 annually, with wife and four children.
Tan Chong vs. Republic (L-19914): P5,000 annually, married with nine children (four still unmarried minors).
Yu Tin vs. Republic (L-19844): P6,600 annually, married with five minor children.

These cases collectively underscored that an income of P4,000.00 a year, particularly when supporting a family, does not meet the threshold typically characterized as a "lucrative trade or occupation."

Whether the decision of the Court of First Instance granting naturalization, though originally favorable to the petitioner, should be considered final given the provision that such decisions are not final and executory until after a two-year lapse.

Whether the petitioner's failure to fully disclose all his former places of residence constitutes sufficient grounds to invalidate the naturalization decision.
Whether the publication of the hearing notice in a newspaper not deemed of general circulation (i.e., the "Daily Record") violates the statutory requirements for notice.
Whether the petitioner’s annual income of P4,000.00, in light of his familial obligations (supporting a wife and four children), can be deemed adequate or if it falls short of being a lucrative trade or occupation, a key element for naturalization approval.