G.R. No. L-20194 - IN RE: Uy vs. Republic

In May 29, 1961, James Uy, also known as Uy Khe Khun, a citizen of Nationalist China, filed a petition for naturalization in the Court of First Instance of Manila.
The petition asserted that:

He was born on September 20, 1939, in the City of Manila.
He was single.
He had resided continuously in the Philippines for at least fifteen (15) years, with at least one year of residence immediately preceding the filing, specifically within the City of Manila.
He possessed all the qualifications required to become a Filipino citizen and was free from any disqualifications prescribed by law.

Appellant claimed to be engaged in employment and reported earning a monthly salary of P180.00.
He further submitted evidence that he held a capital stock in Uy Su Bin and Co., Inc. worth P16,600.00—an inheritance from his deceased father—on which he obtained annual cash dividends amounting to P1,660.00 since 1953.
He also presented the fact that he had a cash deposit or savings of P10,000.00.
His educational background included primary and secondary education at the De La Salle College, a private institution recognized by the Government, indicating that his schooling was not restricted to any particular race or nationality.
He claimed exemption from filing a declaration of intention on the ground that he was born in the Philippines.

A notice of hearing for his naturalization application was properly published.
The Solicitor General opposed the petition, contesting the sufficiency of the evidence submitted.

Appellant did not substantiate a truly lucrative trade, profession, or lawful occupation.

The only record of his employment reviewed was limited to his being employed one month prior to the filing, and it was at a firm controlled by his family (with his uncle as president and manager), which cast doubt on the legitimacy and substantive nature of his employment.
The trial court described the alleged employment as a “mere convenient arrangement” meant to produce a token compliance with the Revised Naturalization Law.

There was an insufficiency of evidence regarding his alleged irreproachable conduct during his entire period of residence in the Philippines.
Evidence indicated that he had been using an alias ("Uy Khe Khun") without proper legal authority:

His name appeared as “Uy James alias Uy Khe Khun” in the Stock and Transfer Book (page 13 of Exhibit E).
A certificate of stock, issued on February 25, 1941, similarly identified him with the alias.
His claim that these entries were the result of his mother’s actions was not persuasive, as the documents established that within his own family he was known both as James Uy and as Uy Khe Khun.

Whether the petitioner proved that he was engaged in a lucrative trade, profession, or lawful occupation, as required by the Revised Naturalization Law.
Whether the evidence of his monthly salary and dividend income was sufficient to meet the statutory income threshold for naturalization.
Whether the petitioner’s conduct during his residence in the Philippines could be deemed irreproachable based on the available evidence.
Whether the use of an alias ("Uy Khe Khun") without lawful authority amounted to misrepresentation and should disqualify him from naturalization.