Title
Chua vs. Republic
Case
G.R. No. L-6269
Decision Date
Mar 30, 1954
Antonio Chua sought naturalization but failed to enroll his minor children in Philippine schools as required. Despite their deaths and claims of war in China, the Supreme Court denied his petition, ruling strict compliance with the law was mandatory, and prior non-compliance was inexcusable.

Case Summary (G.R. No. L-6269)

Key Dates

The appeal pertains to a decision rendered prior to 1990, specifically on March 30, 1954, under the framework of the Revised Naturalization Law in force during that time.

Applicable Law

The primary legal provision in question is paragraph 6, section 2 of the Revised Naturalization Law. This law mandates that applicants for naturalization must enroll their minor children of school age in recognized educational institutions that provide instruction in Philippine history, government, and civics throughout the entirety of the requisite residency period prior to the hearing for naturalization.

Facts of the Case

The government contested the naturalization based solely on the ground that Chua did not meet the educational enrollment requirement for his children. The evidence presented indicated that Chua’s two minor children had died in China in January 1952, roughly four months before the naturalization hearing. This led to a legal inquiry into whether their deaths excused Chua from the requirement of school enrollment.

Argument on Compliance

Chua argued that the deaths of his children exempted him from compliance with the law, asserting that the wartime conditions in China prevented him from bringing them to the Philippines for their education. However, the appellate decision maintained that his failure to enroll them prior to their deaths constituted non-compliance with the legal requirements.

Precedent and Judicial Reasoning

The court referred to a precedent set in the case of Oscar Anglo vs. Republic of the Philippines, where the arguments concerning the effects of war were rejected. The decision reflected that the conditions faced by Chua did not absolve him of the requirements laid out by law. Furthermore, the Court noted that Chua had multiple opportunities to travel to and return from China, suggesting he could have

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