G.R. No. L-19844 - IN RE: Yu Tiu vs. Republic

Frank Yu Tiu, born on December 16, 1929 in Jimenez, Misamis Occidental, filed a petition seeking Philippine citizenship under the provisions of the Pa-redes Law.
He completed his first year of high school at the Jimenez Bethel Institute, which is recognized by the Government.
Tiu is married to Lim Giok Song since February 2, 1952, and together they have five minor children, all born in Cagayan de Oro City, with at least one child already of school age.

Tiu is employed as a storekeeper at Jose Lim Tin Tia Hardware store, earning approximately P5,000.00 per year, with a reported combined income for him and his wife ranging between P6,660.00 and P7,080.00 annually in recent years.
The evidence revealed concerns regarding his modest income, particularly in light of the increasing cost of living, his growing family expenses, and his declining earning trend as a store manager.
His financial condition raised questions about his capacity to support his household without becoming a public charge.

Tiu attested to believing in the principles underlying the Philippine Constitution, having maintained an irreproachable conduct during his residence in the country and not being associated with any group hostile to organized government.
He was also characterized as not being involved in criminal activities, not practicing polygamy, and not suffering from any incurable contagious disease.
His fluency in English and the Cebu Visayan dialect was attested during the trial, which provided a measure of his integration into the community.

Eugenia Laguna, a public school teacher, testified that she had known Tiu since childhood and vouched for his good relations with both the constituted authorities and the local community, promising that he would be a good Filipino citizen.
Pastor C. Sumagang, a long-time acquaintance of Tiu since his early years, also testified to his good behavior, stating that Tiu had never been involved in any criminal prosecution and guaranteed his potential as a good citizen.
However, both witnesses were later critiqued for the limited depth of their acquaintance with Tiu, raising issues about their qualifications to attest reliably to his moral character.

Section 9 of the Revised Naturalization Law requires that upon filing a petition, a notice of the petition and hearing must be posted publicly in a conspicuous place.
The notice is required to include specific details such as the petitioner’s name, birthplace, residence, date and place of arrival in the Philippines, names of proposed witnesses, and the date of hearing.
No evidence of such public posting was provided during the proceedings, which became a significant procedural lapse noted by the Government.

The Government argued that the failure to comply with the mandatory posting requirement affected the validity of the petition given the law’s purpose of ensuring public notice and enabling objections from the community.
Additionally, the Government contended that Tiu’s low income did not meet the economic qualifications necessary to ensure that he would be an asset to the community, especially given his growing family responsibilities.

Whether the failure to post the petition and notice of hearing in a public or conspicuous place pursuant to Section 9 of the Revised Naturalization Law renders the naturalization process invalid.
The significance of such posting in informing the community and allowing for any potential objections in a matter of public interest.

Whether Tiu’s modest earnings, together with his wife’s income, provide a sufficient basis to support a family of seven without risking becoming a public charge.
Whether his financial capacity qualifies him as an asset to the community, particularly given the trend of his declining income and the increased cost of living.

Whether the witnesses’ longstanding acquaintance with Tiu, despite affirming his good character, was sufficient to vouch for his qualifications as a prospective Filipino citizen.
The weight to be given to the testimonial evidence in proving his moral character and integration with the community.