Facts:

• Petition for naturalization of Antonio Dy, a citizen of Nationalist China.
• Republic of the Philippines opposed the naturalization of Dy.
• Grounds for opposition: failure to prove lucrative income or occupation and birth in the Philippines.
• Dy claimed to be employed by his father in their family store, receiving a monthly salary of P80.00 while attending university.
• After graduating, Dy was appointed as the manager of the family business with a salary increase to P250.00.
• Dy also engaged in private tutoring work and contributed written articles to the Chinese Commercial News.
• Dy filed his petition for naturalization on May 26, 1961.

Issue:

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Ruling:

• The Court ruled in favor of the Republic of the Philippines.
• The decision of the lower court was reversed.
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Ratio:

1. The qualifications of an applicant for naturalization should be determined as of the time of filing the petition.

• Dy claimed to have a regular salary of P250.00 a month as the manager of the family store.
• However, this salary increase occurred only one month prior to the filing of his petition.
• Dy's other alleged sources of income, such as private tutoring and fees as a news contributor, were unsteady and irregular.
• The Court found that Dy did not possess a lucrative income or occupation as required by law.

2. Dy failed to prove conclusively that he was born in the Philippines.

• The birth certificate submitted by Dy showed the name Carmen Dy, not Antoni...continue reading