Facts:

• On May 6, 1952, Dee Sam, a Chinese national, applied for naturalization in the Court of First Instance of Manila.
• The court granted his application on January 27, 1953, pending compliance with legal requirements for a naturalization certificate.
• On February 16, 1955, Dee Sam petitioned to take his oath of allegiance, claiming continuous residence in the Philippines since the court's decision.
• He admitted to a two-week trip to Saigon in 1953 to settle his father's estate, who had died in Paris.
• The Solicitor General opposed his petition, arguing that the trip violated Republic Act No. 530.
• Despite the opposition, the court allowed Dee Sam to take his oath, leading to an appeal by the Republic of the Philippines to the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled in favor of the Republic of the Philippines, revoking the lower court's order.
• Dee Sam's two-week absence was deemed a vio...(Unlock)

Ratio:

• The Supreme Court highlighted the necessity for strict compliance with Republic Act No. 530, which mandates a two-year probationary period for naturalization.
• During this period, applicants must not leave the Philippines, must engage in lawful professions, must not have criminal convictions, and must not commit acts against the nation.
• The Court noted that these provisions ensure applicants demonstrate commitment to the Philip...continue reading