Facts:

The case involves the petitioner-appellee, Tan Sen, also known as Cayetano Tan, Cayetano Tan Pao Ho, and Tan Pao Hu, who sought naturalization as a Philippine citizen. The appeal was filed by the Republic of the Philippines, represented by the Solicitor General, against the decision of the Court of First Instance of Misamis Occidental, which had granted Tan's petition for naturalization. Tan was born on February 5, 1919, in Lamua, Amoy, China, and arrived in the Philippines on August 1, 1931, aboard the vessel "Ang Kin." He had not left the country since his arrival. At the time of his petition, filed on August 9, 1961, he was married to Sy Sen, also a Chinese citizen, and they had three children: Lilia, Betty, and Wayne. The family resided in Sinacaban, Misamis Occidental, where Tan was engaged in the copra trading business, claiming an average annual net income exceeding P4,000. During the hearing, he demonstrated some proficiency in English and the Visayan di...

Facts:

Header: Background and Personal Information
Petitioner-appellee, Tan Sen alias Cayetano Tan alias Cayetano Tan Pao Ho alias Tan Pao Hu, is a native of China, born on February 5, 1919, in Lamua, Amoy. He arrived in the Philippines on August 1, 1931, aboard the vessel "Ang Kin" and has remained in the country since then. He is married to Sy Sen alias Sima, a Chinese citizen, and has three children—Lilia, Betty, and Wayne—who were enrolled in schools in Misamis Occidental. At the time of the hearing, the family resided in Sinacaban, Misamis Occidental, where petitioner was engaged in buying and selling copra.
Header: Petition Details
Petitioner filed his petition for naturalization on August 9, 1961, claiming an average annual net income of more than P4,000. During the hearing, he testified in English and demonstrated some proficiency in the Visayan dialect. Two witnesses, Jose Contreras and Telesforo Simbajon, vouched for his good moral character.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Non-Compliance with Publication Requirements
   The Court held that the affidavit by the publisher of "Nueva Era" stating its general circulation in the Philippines was insufficient. Positive evidence proving its general circulation in Misamis Occidental was required, as the purpose of publication was to inform local officers and citizens about the petition. Since "Nueva Era" was published in Spanish, not in English or the local dialect, and lacked direct proof of circulation in the province, the publication did not fulfill the law’s objective.
2. Income Deficiency
   The Court found petitioner’s income in 1961 insufficient, and the sudden increase in 1962 was suspicious, suggesting it was intended to address the deficiency for naturalization purposes.
3. Violation of the Anti-Alias Law
   The Court ruled that petitioner’s use of multiple aliases without judicial authorization was a clear violation of the Anti-Alias Law, which justified the denial of his application. This was supported by precedents (Ong Hock Lian vs. Republic, Wang I Fu vs. Republic, Koa Gui vs. Republic, Lim Bun vs. Republic, and Ng Liam Ken vs. Republic).