Title
IN RE: Tan Sen vs. Republic
Case
G.R. No. L-23181
Decision Date
Oct 24, 1967
A Chinese national’s naturalization petition was denied due to non-compliance with publication requirements, insufficient income, and unauthorized use of aliases, violating the Anti-Alias Law.
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Case Summary (G.R. No. L-23181)

Compliance with Publication Requirements

  • The petitioner must provide positive evidence that the newspaper used for publication, "Nueva Era," is of general circulation in Misamis Occidental.
  • An affidavit from the newspaper's editor is insufficient to prove compliance with the law.
  • The law mandates that the newspaper must be of general circulation in the province where the petitioner resides to ensure public awareness of the naturalization petition.
  • The publication in a language not commonly used in the province (Spanish) further undermines its effectiveness in serving the law's purpose.

Scrutiny of Income Sources

  • The petitioner reported a net income of P3,037.44 in 1961, which significantly increased to over P10,000.00 in 1962, alongside an additional bonus of P1,000.00.
  • This sudden increase of more than 100% raises suspicions that the income was artificially inflated to meet the financial requirements for naturalization.
  • The Solicitor General argues that such discrepancies in income should be closely examined to determine the legitimacy of the petitioner's financial standing.

Violation of the Anti-Alias Law

  • The petitioner admitted to using three aliases without judicial authorization, which constitutes a violation of the Anti-Alias Law (Commonwealth Act No. 142).
  • The use of aliases is documented in various official records, including marriage and birth certificates, but lacks legal validation.
  • This violation is deemed significant enough to warrant the denial of the naturalization application, as established in previous case law.

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