G.R. No. L-21197 - IN RE: Ong Hock Lian vs. Republic

Ong Hock Lian, also known as Julian Ong, petitioned for naturalization as a citizen of the Philippines.
The petitioner is originally a citizen of the Republic of China who arrived in the Philippines on April 30, 1927.
His residential history includes living in Zamboanga City and, since March 1, 1940, in Dumaguete City.

He is married to Tan Ko Kiem (also known as Alice Tan), a Chinese national, and they have three children.
Two of his children are school-aged and enrolled at St. Paul’s College in Dumaguete City, an institution that recognizes students irrespective of race or nationality while teaching Philippine history, government, and civics.
His educational background includes finishing the first year of high school at the Zamboanga Chinese High School; he is also conversant in English and the Cebuano-Visayan dialect.

Ong is a merchant by occupation and operates a store in Colon Street, Dumaguete City, dealing with rice, corn, and general merchandise.
The petition also detailed his business assets, which include two cargo trucks valued at ₱17,000 and office equipment worth about ₱200.
Financial records provided show his net income as follows: ₱5,939.36 in 1958; ₱4,114.49 in 1959; and ₱5,659.30 in 1960.

To prove his qualifications under the Naturalization Law, the petitioner submitted various documents including:

Tax clearances
Police clearances
Clearances from the Philippine Constabulary, the City Fiscal, the Provincial Fiscal, the Court of First Instance of Negros Oriental, and the Municipal Court of Dumaguete City
A medical certificate issued by the City Health Officer

The evidence was aimed at establishing that he possessed none of the disqualifications listed in the Naturalization Law.

Although there were four issues raised by the Solicitor General on appeal, only the following three error assignments were considered by the court for purposes of the appeal:

The petition’s failure to hold that the use of an alias “Julian Ong” was unauthorized under the law.
The failure to hold that the petitioner did not report his true income.
The failure to hold that the petitioner lacked a lucrative occupation due to insufficient earnings.

Whether the lower court erred in not holding that the petitioner’s use of an alias “Julian Ong” was unauthorized, considering that no evidence showed he had been baptized with or known by that name since childhood, nor that it was authorized by a competent court.
Whether the lower court erred in not holding that the petitioner failed to report his true income, especially given the discrepancies between his declared salaries and income tax returns.
Whether the lower court erred in not holding that the petitioner does not have a lucrative occupation, based on his annual net income falling short of the legally required threshold.