Facts:

The case involves Anacleto Lim, also known as Lim Eng Chuan, as the petitioner and appellee, against the Republic of the Philippines, the oppositor and appellant. The proceedings took place in the Court of First Instance of Cebu, presided over by Judge Amador E. Gomez. The petitioner filed his application for naturalization on June 15, 1959, and a favorable judgment was rendered on November 30, 1960. On December 7, 1962, Lim filed a motion to introduce evidence under Republic Act 530 and requested to take his oath of allegiance. The court granted this motion, issuing an order on January 19, 1963, which allowed Lim to take his oath of allegiance as a naturalized citizen. Lim took the oath on the same day, and a certificate of naturalization (Certificate No. 359) was issued to him on January 22, 1963. The government was notified of this order on February 7, 1963, and subsequently filed an appeal on February 15, 1963. The lower court, while believing the appeal to be frivolous, ...

Facts:

Background of the Case

• The case involves Anacleto Lim, alias Lim Eng Chuan, who filed a petition for naturalization to become a citizen of the Philippines. The exact date of filing is not indicated in the records, but it is noted that the petition was filed on or before June 15, 1959.
• The Court of First Instance of Cebu rendered a favorable judgment on November 30, 1960, granting Lim's petition for naturalization.

Motion to Take Oath of Allegiance

• On December 7, 1962, Lim filed a motion to introduce evidence pursuant to Republic Act 530 and to take his oath of allegiance.
• The lower court issued an order on January 19, 1963, declaring Lim entitled to take his oath as a Filipino citizen. On the same day, Lim took his oath of allegiance before the presiding judge.
• A certificate of naturalization (Certificate No. 359) was issued to Lim on January 22, 1963.

Government's Appeal

• The Government was notified of the order on February 7, 1963, and filed an appeal on February 15, 1963.
• The lower court approved the record on appeal, despite considering the appeal frivolous, as the Supreme Court had previously entertained similar appeals.

Petitioner's Financial Status

• Lim claimed co-ownership of a residential house valued at P13,000.00 and ownership of shares of stock in Lim Bonfing y Hermanos, also valued at P13,000.00, inherited from his deceased father.
• However, no settlement of the estate was shown, and the shares of stock were not proven to be income-producing.
• Lim was employed at the Cebu Branch of the Philippine Bank of Communications, earning a salary, bonuses, allowances, overtime, and vacation pay. His annual salary in 1959 was P1,620.00 and P2,280.00 in 1960.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Financial Qualifications for Naturalization: For purposes of naturalization, an applicant's income is assessed as of the time of filing the petition. Contingent income, such as bonuses and allowances, cannot be included in the computation of income. Lim's annual salary of P1,620.00 (1959) and P2,280.00 (1960) was deemed insufficient to qualify as a lucrative occupation.
2. Premature Administration of Oath: The lower court's immediate administration of the oath of allegiance on the same day the order was issued was improper. This action deprived the Government of its right to appeal and rendered the appeal process ineffective.
3. Nullity of Naturalization Certificate: The certificate of naturalization issued to Lim was declared null and void due to the failure to meet the financial qualifications and the procedural impropriety in administering the oath.