Title
IN RE: Chu Bok vs. Republic
Case
G.R. No. L-19111
Decision Date
Jun 22, 1965
Chui Bok, a Chinese merchant in Dipolog, sought Philippine citizenship but was denied due to insufficient income and unauthorized alias use.
lack of lucrative occupation
alias without authority
naturalization
A

Case Summary (G.R. No. L-19111)

Factual Background

The evidence presented by petitioner showed that he was born on June 5, 1913 in Tangchich, China. He arrived in Manila on June 30, 1930 aboard the S/S Angking, and after a stay of four months, he moved to Cebu City, where he resided until 1936. From 1936 to 1938, he engaged in general merchandising on board an inter-island boat plying between Cebu City and Dipolog. During that period, he met and married Maria del Rosario Liong, and the couple later settled permanently in Dipolog, Zamboanga del Norte.

Petitioner and his wife had five children: Justo, Carmelita, Julita, Rosita, and Manuel. Petitioner also alleged that his first four children, who were of school age, studied in schools recognized by the Government where Philippine Government, History and Civics were taught. He testified that he spoke English and the Cebuano-Visayan dialect. He further submitted proof that he had conducted himself in a proper and irreproachable manner during his entire period of residence in the Philippines, and he attempted to show social mingling with Filipinos and contributions of funds to civic and charitable organizations. He operated a store known as David Trading located at Dipolog.

Proceedings in the Court of First Instance

On the basis of the findings, the Court of First Instance of Zamboanga del Norte declared petitioner qualified to be admitted as a citizen of the Philippines and granted the application.

Issues Raised on Appeal

On appeal, the Solicitor General challenged the grant of naturalization and relied on several grounds. The Supreme Court noted, for speedy disposition, that not all grounds would require discussion. The case thus turned principally on whether petitioner satisfied the statutory requirements on the character and the economic aspect of naturalization, as reflected in the evidence presented.

The Parties’ Contentions

The Solicitor General’s position focused on petitioner’s alleged lack of lucrative income and on petitioner’s use of an alias without authority. Petitioner claimed that his net income from the operation of his store was P5,000, relying on his income tax returns for 1956, 1957, 1958, 1959, and 1960. The returns showed that, while petitioner’s net income in 1957 was P6,892, it declined in the succeeding years, with net incomes reflected as 1958—P2,967.35; 1959—P2,388.50; and 1960—P2,098.78.

Petitioner argued that the earlier doctrine relied upon by the Government—derived from Keng Giok vs. Republic, G.R. No. L-13347, August 31, 1961—could not apply to his case because the cost of living in Manila was higher than in Zamboanga del Norte. In response, the Supreme Court emphasized that even on petitioner’s own figures, the gap between the income levels was not negligible and that the statutory standard required income sufficient to maintain a family.

On the issue of character, the Government argued that petitioner’s use of an alias without authority, as provided for in Commonwealth Act No. 142, violated the Anti-Alias Law and reflected a lack of irreproachable character, citing Lim Bun vs. Republic of the Philippines, G.R. No. L-12822, April 26, 1961.

The Supreme Court’s Reasoning

In addressing the income requirement, the Supreme Court treated the case as closely analogous to Keng Giok vs. Republic, where it held that the income of an applicant residing in Manila was not lucrative in view of the size of the family and the yearly decline in net income. The Supreme Court found that petitioner’s situation likewise involved a wife and five children and that his net income was declining as reflected by his tax returns.

Petitioner’s attempt to distinguish Keng Giok by invoking differences in the cost of living was rejected. The Supreme Court reasoned that in Keng Giok, the net income found insufficient was P8,000, whereas petitioner alleged a net income of about P5,000, and that the difference was more than enough to cover any cost-of-living disparity between Manila and Zamboanga del Norte.

The Court further fortified its view by referencing the Court’s more recent rulings. In Uy Ching Ho vs. Republic, G.R. No. L-19582, March 26, 1965, it had held that an income of P7,799.34 was not regarded as lucrative for an applicant with a wife and five minor children living in Dumaguete. It also cited Tan vs. Republic, G.R. No. L-19580, April 30, 1965, and Yap vs. Republic, G.R. No. L-19649, April 30, 1965, reiterating that an alien must have income decent enough to maintain a family to be admitted to Philippine citizenship. Applying these teachings, the Supreme Court held that petitioner’s income, as shown by the returns, did not meet the requirement for a lucrative and sufficient livelihood.

On the character aspect, the Supreme Court held that petitioner’s use of an alias without authority, as prohibited in Commonwealth Act No. 142, constituted a clear violation of the Anti-Alias Law. It concluded that this violation further disqualified petitioner by showing that he was not a person of irreproachable character, consistent with Lim Bun vs. Republic of the Philippines.

Disposition of the Appeal

The Supreme Court reversed the decision of the Court of First Instance of Zamboanga del Norte granting naturalization. It ordered that costs be charged against the petitioner-

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