G.R. No. L-15819 - IN RE: Wang I Fu vs. Republic

Wang I Fu, a Chinese national, was born on February 15, 1918, in Chingkang, China.
He arrived in the Philippines on May 14, 1934, and has continuously resided there since.
He is married to Maria Sun, also of Chinese origin, and they have five children: Maria Teresita, George, Eduardo, Gladys, and Maria Nancy.
His involvement in the glassware business yields an average annual income of P8,000.00.
He is proficient in both English and Tagalog, indicating his capacity to communicate in the languages commonly used in the Philippines.

Despite meeting some of the basic qualifications required for naturalization—including no conviction of crimes involving moral turpitude or evidence of violent proclivities—the petitioner’s conduct raised several concerns.
His education was obtained in the Anglo-Chinese School, where he did not mix with Filipino classmates, and his residence was reportedly in predominantly Chinese neighborhoods.
All his children are enrolled in Chinese educational institutions (Immaculate Conception Anglo-Chinese Academy and Huang Chi School), further contributing to the perception that he did not seek cultural assimilation with the Filipino community.

The petitioner has been found to use multiple aliases, with his name appearing variably as Wang I Fu, George Wang I Fu, George Ong, and Ong Hay Kuan in different documents (e.g., landing certificate, immigrant certificate of residence, marriage contract, and the birth certificates of his children).
His use of aliases was not explained nor was there evidence of authorization as required by the Alias Law (Commonwealth Act No. 142), thereby casting doubt on his transparency and reliability.

He did not send financial support to her despite having a prosperous business, and
He exhibited contradictory testimonies regarding his communication and concern for her welfare.

His membership in the Philippine-Chinese Glassware Merchants Association, an organization that passed a resolution against the Filipino First Policy, and his employment practices (favoring Chinese employees over Filipinos) further suggest a preference for association with the Chinese community over assimilating with Filipino society.

The witnesses presented by the petitioner, who had known him only since the mid-1940s, provided uncorroborated assertions regarding his conduct over the longer period since 1934.
This gap in reliable testimony raised doubts about whether his conduct during his entire residence in the Philippines met the standard of moral irreproachability required for naturalization.

Whether the petitioner’s unaccounted use of multiple aliases, in violation of the Alias Law (Commonwealth Act No. 142), constitutes a basis for denying his petition for naturalization.

Whether the petitioner has genuinely embraced the customs, traditions, and ideals of the Filipino people, given his educational choices for his children, membership in culturally exclusive organizations, and residential patterns.
Whether his lack of communication or concern for his mother in China reflects a deficiency in the filial and national sentiments expected of a naturalized Filipino citizen.

Whether the limited period of acquaintance of the petitioner’s witnesses, dating only as far back as the mid-1940s, is sufficient to demonstrate that his conduct has been irreproachable throughout his residence in the Philippines.