G.R. No. L-20623 - IN RE: Law Tai vs. Republic

Petitioner: Law Tai alias Vicente Lo (christened Vicente Sandiko Lo), a citizen of the Republic of China, born on May 17, 1923, in Amoy, China.
Arrival in the Philippines: Arrived in Manila on October 4, 1930, by boat.
Marriage and Family: Married Salvacion T. Cerdena, a Filipina, on May 12, 1948, and the couple has six minor children.
Business and Income: Established a business in 1950 under the name Adventure Supply; reported an annual income of P5,499.58 at the time of his petition.

After arriving in Manila, he relocated to Laoag, Ilocos Norte, and resided there for less than two years.

In 1932, he returned to Amoy, China, visiting his parents for less than four months.
After his visit, he returned to Manila for about two months before proceeding to Bacolod, Negros Occidental, where he resided for approximately 4 or 5 years.

Post-liberation, he moved to Romblon, Romblon, which he indicated as his present place of residence in his petition.
Approximately two or three years after arriving in Romblon, he began employment as a purser on board the ship "General Del Pilar."

In 1948, he traveled again to Amoy with his wife to pay respects to his parents.
He also took a trip to Hongkong to visit a sister, although the duration of this visit is not clearly recorded.

Petitioner filed a petition for naturalization on January 14, 1961, before the Court of First Instance of Romblon.
The petition sought admission to Philippine citizenship, relying on his long period of residence (30 years, 3 months, and 10 days from his arrival in 1930).

Petitioner did not file a declaration of intention as mandated by the Naturalization Law, claiming exemption on the basis of his extended residence.

The application listed only Romblon, Romblon as his residence while omitting former residencies (Laoag and Bacolod).

His annual income was deemed insufficient ("not lucrative") relative to his familial obligations and the prevailing cost of living.

Whether petitioner Law Tai alias Vicente Lo satisfied the requirement for continuous and substantial residence in the Philippines, particularly in light of his multiple absences abroad and failure to file a declaration of intention as set forth in the Naturalization Law.
Whether the absences from the Philippines—specifically the trips to Amoy (first and subsequent) and Hongkong—can be categorically deemed short enough such that they do not disrupt the continuity of residence required for naturalization.
Whether the failure to disclose or list all his former places of residence (i.e., Laoag and Bacolod) in his application constitutes a fatal defect in his petition for naturalization.
Whether petitioner’s reported annual income of P5,499.58 was sufficient to meet the "lucrative" requirement given his financial obligations as a married man with six children.