Case Summary (G.R. No. L-20479)
Background of the Petition
Chua Eng Hok filed his petition for naturalization on June 6, 1959. He claimed residency at 1764 Sisa St., Sampaloc, Manila, while disclosing previous residences in Tondo, San Pablo City, and Camarines Sur. He asserted his birth on March 14, 1925, in Chuansio, Chinkiang, China, and his current status as a subject of the Republic of China. Chua reported being married to Osmundita Avila Palomar, a Filipino citizen, and indicated he had four children. He also declared an annual income of P4,000 from his employment at the Central Manufacturing Corporation and professed his belief in the principles of the Philippine Constitution.
Naturalization Law and Its Implications
Under the Naturalization Law, specifically Commonwealth Act No. 473 as amended by Republic Act No. 530, the decision in naturalization cases is not final until two years have elapsed. Consequently, on October 12, 1962, the Republic filed a petition to object to Chua's oath-taking as a citizen, citing grounds such as failure to disclose all former residences, publication of notice in a newspaper lacking general circulation, and insufficient income.
Grounds for Opposition to Naturalization
The objections raised by the Republic included the petitioner’s omission of former residences, the choice of newspaper for the notice, and the assertion that an annual income of P4,000 supporting a family of six was insufficiently lucrative. The Court noted the argument regarding income as particularly compelling, referencing previous cases that established a threshold for what constitutes a lucrative occupation.
Judicial Reasoning on Naturalization Income
The Court referred to past decisions, concluding that a yearly income of P4,000 is inadequate for a family of Chua's size. Specifically, the Court cited similar cases where similar income levels did not satisfy the naturalization requirements. It reiterated the principle that citizenship is a significant and valued status, necessitating strict a
...continue readingCase Syllabus (G.R. No. L-20479)
Case Overview
- This case is an appeal filed by the Solicitor General against the decision of the Court of First Instance of Manila, which granted the naturalization application of Chua Eng Hok.
- The decision from the lower court was issued on May 3, 1960, but was not deemed final and executory until two years had passed, as stipulated in the Naturalization Law.
Background of the Petitioner
- Chua Eng Hok filed his petition for naturalization on June 6, 1959.
- He claimed residency at 1764 Sisa St., Sampaloc, Manila, with previous residences including:
- 1327 Sanchez Ext., Tondo, Manila
- San Pablo City, Laguna
- Libmanan, Camarines Sur
- Born on March 14, 1925, in Chuansio, Chinkiang, China, he remained a subject of the Republic of China at the time of the petition.
- Chua is married to Osmundita Avila Palomar, a Filipino citizen, and they reside together in Manila.
- The couple has four children, with Chua's annual income reported as P4,000.00 from employment at the Central Manufacturing Corporation.
- He attested to believing in the principles of the Philippine Constitution and demonstrated proper conduct in civic dealings.
Proceedings and Initial Decision
- The Court of First Instance of Manila held a hearing where Chua and c