G.R. No. L-20895 - IN RE: Hong Chiong Yu vs. Republic

Ramon Hong Chiong Yu, also known as Ramon L. Young, petitioned for naturalization as a citizen of the Philippines.
He was born on January 15, 1934, in the municipality of Capiz (now Roxas City), Province of Capiz, to Chinese parents.
Petitioner has continuously resided in the Philippines since birth.

Petitioner completed his elementary education at Aklan College, a Catholic institution, and his high school education at Northwestern Visayan College, both located in Kalibo, Aklan.
At the time of the proceedings, he resided in Pinamalayan, Oriental Mindoro, while pursuing his fourth year in chemical engineering at the Mapua Institute of Technology in Manila.
He was employed as a salesman at the Globe Bicycle Store in Manila, as evidenced by his petition filed on October 13, 1959, which indicated an annual income of P1,800.00.

Two local witnesses, former Congressman Conrado Morente and Mayor Dominador Madrid of Pinamalayan, testified in support of petitioner’s good moral character and irreproachable conduct.
Evidence included the petitioner’s enrollment, residential history, educational background, and character testimonies.

Failing to note the petitioner’s former place or places of residence.
Accepting petitioner's declared annual income of only P1,800.00 (or approximately P150.00 per month) as sufficient.
Overlooking the fact that petitioner was using an alias without judicial authority.

The petitioner was reported to have an additional income of P100.00 per month from tutorial classes, raising his monthly income to P250.00.

The naturalization law requires an applicant to have a lucrative occupation or calling, which is substantiated by a sufficient income.
Precedent cases (e.g., Sy Ang Hoc, Richard Velasco, Tan, Zacarias, and others) consistently held that monthly incomes of P150.00, P200.00, or even P250.00 do not satisfy the statutory requirement.
Additional cases further established that even a monthly income of P1,300.00 could be deemed insufficient for naturalization.

Whether the petitioner’s failure to indicate his former place or places of residence in his petition constitutes a ground for denying naturalization.

The evidence presented on this point was unclear, raising questions about its weight.

Whether the petitioner’s declared income—P1,800.00 annually (or P150.00 monthly), augmented by an additional P100.00 monthly—is sufficient to meet the statutory requirement of possessing a lucrative occupation or calling.

Whether the petitioner's use of an alias without judicial authority affects the validity of his petition for naturalization.

The issue of the alias was also cited by the Solicitor General as a basis for the error in granting the petition.