Title
IN RE: Lim So vs. Republic
Case
G.R. No. L-2645
Decision Date
May 28, 1951
A Chinese merchant, residing in the Philippines for 40 years, married to a Filipina, was granted naturalization despite China's renunciation requirement, as Philippine law does not mandate foreign approval.
A

Case Summary (G.R. No. 185063)

Relevant Facts

Alfonso R. Lim So was born in China in 1894 and immigrated to the Philippines in 1912 as a merchant. He has resided in the Philippines for almost forty years, married a Filipino woman, and had two children who are now adults and educated in local schools. Lim So owns land valued over P10,000 and is engaged in business. He is proficient in the Cebuano dialect, as well as having some knowledge of English and Spanish.

Legal Framework

The application for naturalization is governed by Commonwealth Act 473, as amended, known as the Revised Naturalization Law. The trial court found that Lim So met all the qualifications outlined in the law and had no disqualifications, thus deemed him eligible for naturalization as a Filipino citizen.

Opposition to Naturalization

The Solicitor General acknowledged Lim So's qualifications but contested the decision based on Lim So's inability to renounce his Chinese citizenship effectively. The objection stemmed from Article 11, Chapter III of the Chinese Law of Nationality, which requires permission from the Chinese Ministry of Interior to renounce citizenship.

Prior Jurisprudence

The court referenced previous decisions (notably, Parado vs. Republic of the Philippines, King vs. Republic of the Philippines, and Johnny Chausintek vs. Republic of the Philippines) which established that obtaining permission from the Chinese Ministry of Interior is not a prerequisite for naturalization under Philippine law. This precedential bite was significant because it underscored that the issues surrounding renunciation of citizenship should be viewed within the framework of Philippine law, rather than Chinese law.

Decision and Outcome

The court affirmed the trial court's decision to grant Lim So'

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