G.R. No. L-3354 - IN RE: Tan Hi vs. Republic

Tan Hi, a Chinese citizen by birth, was born on April 10, 1902, in Amoy, China.
He arrived in the Philippines on March 1, 1918, and thereafter established his residence in the country, notwithstanding frequent trips back to China.

While in China, Tan Hi maintained a relationship with a Chinese woman, with whom he had five children.

Two of these children are married.
The remaining three, aged 16, 14, and 12, are minors and are under the care of his mother in China.

Tan Hi claimed that his Chinese wife (with whom he had never been legally married) died before 1941.
Subsequently, he married a Filipino woman, Catalina Lua Kaberte, in the Philippines and had four children with her:

In his application for naturalization, Tan Hi stated that he only had four children – namely those he claimed were from his legally recognized marriage to Catalina Lua Kaberte.
His "Declaration of Intention" (Exhibit F) mentioned only the children residing in the Philippines, omitting any reference to his children in China, particularly the three minor children.
When questioned about his marriage to Catalina, Tan Hi failed to produce the required marriage certificate despite his lawyers’ assurances to present one as Exhibit L.
Later during the hearing, his counsel obtained permission to amend paragraph 10 of the application to include a statement listing Lydia and Estrellita as natural children attending recognized Philippine schools, thereby raising further doubts regarding the legitimacy of his marital claims.

The evidence presented showed a pattern of irregularity and equivocal conduct in Tan Hi’s representations regarding his marital status and children.
The inherent contradiction between his statements, such as asserting never to have married the Chinese woman while simultaneously recognizing his children from that relationship as legitimate, fueled doubts about his candor.
A critical fact highlighted was the existence of three minor children in China, whom Tan Hi intended to bring to the Philippines should his naturalization be approved, which would automatically convert their citizenship status.

Whether Tan Hi’s failure to truthfully and consistently declare all of his children and marital relationships undermines his claim to good moral character, as required by the Naturalization Law.
Whether the omission of his minor children residing in China from his declaration, combined with the failure to produce a valid marriage certificate, constitutes grounds to question the applicant’s integrity and eligibility for naturalization.
Whether the non-enrollment of all minor children of school age in recognized Philippine public or private schools, as mandated by the Revised Naturalization Law, bars the approval of his naturalization application.