G.R. No. L-20866 - Lee Ong vs. Republic

Loreto Lee Ong, a Chinese citizen, was born on December 10, 1923, in Naga City, Camarines Sur, Philippines.
He possessed both an Alien Certificate of Registration and a Native Born Certificate of Residence issued by the Bureau of Immigration.
From birth, Ong did not leave the Philippines except for a brief evacuation to the hinterland during the Japanese occupation, and he maintained continuous residence in Naga City.
He is survived by family members, including two brothers and three sisters, with his mother still living.

Ong presented evidence that he was employed as the Assistant Manager and Paymaster of Venancio Hardware, a business owned and controlled by his brother, Venancio.
The evidence showed that his monthly salary was only P200.00, which the court viewed with skepticism regarding its lucrativeness.
He concurrently submitted income tax returns for the years 1952 to 1960, indicating net incomes ranging from P1,885.84 to P4,148.60 despite the modest monthly salary figure.
Additionally, he showed ownership of a building on a piece of land owned by a Chinese Commercial Company and proof of payment for real estate taxes.

Ong demonstrated his ability to speak and write both English and the local dialect.
He professed belief in the principles underlying the Philippine Constitution and declared no opposition to organized government.
He affirmed he was not involved in or promoting violence, polygamy, or any undeclared practices, and maintained that his conduct was irreproachable both in his community and in his dealings with the government.

Ong filed his petition for naturalization on April 11, 1960, with the Court of First Instance of Camarines Sur, which, after publication and hearing, rendered a decision denying his petition on March 5, 1962.
His subsequent motion for reconsideration was denied, prompting him to elevate the matter on appeal.
In support of his appeal, Ong alleged several errors committed by the lower court, particularly:

The erroneous dismissal of the exemptions claimed in his income tax returns for 1952 and 1955 as fraudulent and illegal.
The finding that the exemptions claimed for his two sisters in the 1954 and 1955 returns were falsely represented.
The misinterpretation of his income tax returns for the years 1958, 1959, and 1960, which allegedly contained further fraudulent misrepresentations and omissions.
The improper application of precedents in the cases of Lim Siong v. Republic of the Philippines and Lao Lian Su.
The denial of his motion for reconsideration and new trial, coupled with the overall denial of his petition for naturalization.

Whether the trial court erred in holding that the petitioner’s income tax returns for the years 1952, 1954, 1955, 1958, 1959, and 1960 contained fraudulent and illegal exemptions and misrepresentations.
Whether the evidence submitted regarding his alleged employment as Assistant Manager and Paymaster at Venancio Hardware was sufficient and convincing to establish he earned a lucrative and gainful income.
Whether the apparent discrepancies between his declared monthly salary of P200.00 and the higher net income figures stated in his income tax returns undermine his claim of having a substantial and continuous source of income.
Whether the lower court erred in applying the precedents set by Lim Siong v. Republic of the Philippines and Lao Lian Su to his case.
Whether the denial of his motion for reconsideration and new trial, and by extension the petition for naturalization, was justified based on the evidence and the applicable legal standards.