Title
IN RE: Sia vs. Republic
Case
G.R. No. L-20290
Decision Date
Aug 31, 1965
Pantaleon Sia's naturalization application was denied due to failure to meet the exemption requirements for filing a declaration of intention and insufficient income.
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Case Digest (G.R. No. L-20290)

Facts:

  • Pantaleon Sia, also known as Alfredo Sia, is the petitioner-appellee.
  • The Republic of the Philippines is the oppositor-appellant.
  • An appeal was filed on August 31, 1965, against a decision from the Court of First Instance of Manila in Civil Case No. 46164, which granted Sia's naturalization petition.
  • Sia applied for naturalization on January 30, 1961, without a prior declaration of intention, claiming exemption due to his birth in the Philippines, continuous residence, and completion of secondary education.
  • He was born on July 27, 1936, in Tayabas, Quezon, to Chinese parents.
  • Sia attended various schools, including Francisco Balagtas Elementary School and Chia-Nan School, and graduated from Far Eastern University in March 1959.
  • At the time of the hearing, he was enrolled at the University of the East.
  • Sia worked in different roles, earning a monthly salary that increased over time.
  • He lived with his parents without paying for board and lodging but managed his educational expenses.
  • He mingled with Filipinos, claimed adherence to the Philippine Constitution, had no criminal record, and obtained clearances from government agencies.
  • Sia expressed willingness to renounce allegiance to China and confirmed he had not filed other naturalization petitions.
  • The government appealed, questioning his exemption from the declaration of intention and the sufficiency of his income.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that Pantaleon Sia was not exempt from the requirement of filing a declaration of intention.
  • The Court also ruled that Sia did not po...(Unlock)

Ratio:

  • The Supreme Court emphasized that the burden of proof lies with the applicant to demonstrate compliance with naturalization requirements.
  • Sia failed to provide adequate evidence that his primary school was inclusive of all races, which is necessary for exemption from the declaration of intention.
  • The Court referenced prior rulings requiring applicants to show their educational institutions included Filipino students to absorb l...continue reading

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