Case Digest (G.R. No. L-17748)
Facts:
Manuel Yu, a petitioner and appellant in this case, sought naturalization as a Philippine citizen under G.R. No. L-17748. Born on March 22, 1934, in Manila to Chinese parents, he resided with his mother, Ong Kim, at 1319 Soler Street. At the time of trial, he was still single and had remained continuously in the Philippines, except for a brief vacation to China during childhood. Manuel Yu was registered as a citizen of China with the embassy and possessed the requisite documentation including a certificate of registration and an immigrant certificate of residence from the Bureau of Immigration. He was educated at local schools, completing elementary at the Chinese Republican School and high school at Quezon College, eventually attending a semester at the Mapua Institute of Technology.During the hearing, evidence indicated that Yu upheld the principles of the Philippine Constitution and conducted himself properly in his community and relations with the government. He demonstrat
Case Digest (G.R. No. L-17748)
Facts:
- Personal Background and Citizenship Status
- Manuel Yu was born on March 22, 1934, in Manila to Chinese parents.
- He has continuously resided in the Philippines, except for a brief vacation in China during his childhood.
- Despite his birth in Manila and long residence, he is registered with the Embassy of the Republic of China and holds a certificate of registration along with an immigrant certificate of residence issued by the Bureau of Immigration.
- Yu is proficient in both Tagalog and English, as evidenced by his language proficiency records.
- Educational and Social Integration
- His primary education was completed at the Chinese Republican School, Manila.
- He attended high school at Quezon College, Manila, and pursued a semester of commerce at the Mapua Institute of Technology.
- The evidence shows that Yu possesses a genuine belief in the principles underlying the Philippine Constitution.
- He has conducted himself in a proper and irreproachable manner, maintaining harmonious relations with both the constituted government and the community.
- He has integrated socially with Filipinos and demonstrated a sincere desire to learn and embrace their customs, traditions, and ideals.
- Moral Character and Affiliations
- Yu is not affiliated with any organization or group that upholds doctrines opposing organized government or promotes violence and personal assault as means to achieve political objectives.
- He is not a polygamist and rejects the practice of polygamy.
- He has never been convicted of any crime involving moral turpitude nor has he been charged with any offense.
- There is also evidence indicating that he is free from mental alienation or any incurable contagious disease.
- Employment and Economic Standing
- Yu claims employment as a sales representative at the Victory Steel Chair Factory, which is owned by his mother, Ong Kim, and located at 1319 Soler Street, Manila.
- His evidence indicates an annual earning of P1,440.00, equating to a monthly income of P120.00.
- His employment evidence is primarily based on his own testimony and a written statement by his mother, which was not corroborated by her on the witness stand regarding the details of his birth.
- There is an allegation that the free board and lodging provided by his mother (valued at P60.00 monthly) should be added to his cash earnings; however, even with this addition, his income remains below the threshold required for a lucrative trade or occupation under the prevailing legal standards.
- Naturalization Qualification Requirement
- Although Yu meets several qualifications required for naturalization, his case is marred by the deficiency in establishing a lucrative and lawful occupation.
- The statutory requirement for naturalization mandates that the petitioner must provide satisfactory proof of actual engagement in a trade or occupation that is financially adequate.
Issues:
- Whether the evidence presented by Manuel Yu sufficiently demonstrates that he is gainfully employed in a lucrative and lawful occupation for the purposes of naturalization.
- Whether the reliance on self-testimony and uncorroborated written statements (particularly those provided by his mother) satisfies the evidentiary requirement to prove regular and substantial earnings.
- Whether the inclusion of non-monetary benefits (i.e., board and lodging) can be legitimately aggregated with his cash salary to meet the statutory threshold for a lucrative occupation.
- How the legal standards and precedents, including those from Lo Chicombing vs. Republic, Sy Ang Hoc vs. Republic, Tan vs. Republic, Sy Pinero vs. Republic, and Ong vs. Republic, apply to the evaluation of his employment and income.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)