Title
IN RE: Yu Tiu vs. Republic
Case
G.R. No. L-19844
Decision Date
Jun 30, 1965
Frank Yu Tiu's naturalization petition denied due to non-compliance with publication requirements, insufficient income, and inadequate witness qualifications.

Case Summary (G.R. No. L-19844)

Facts of the Case

Frank Yu Tiu was born on December 16, 1929, in Jimenez, Misamis Occidental. He completed his first year of high school at an institution recognized by the government and married Lim Giok Song on February 2, 1952. Tiu has been living continuously in the Philippines and works as a storekeeper at Jose Lim Tin Tia Hardware, earning an annual salary of P5,000.00. Tiu's family includes five minor children. His claim to citizenship is supported by his assertion of belief in the principles of the Constitution, good conduct, social integration, and the absence of criminal convictions or incurable contagious diseases.

Testimonies

The testimonies provided by Eugenia Laguna and Pastor C. Sumagang were presented to support Tiu's petition. Laguna, having known Tiu since childhood, attested to his good character and relations with the community. Similarly, Sumagang confirmed Tiu's commendable conduct and stated that he had never witnessed any criminal prosecution involving him. Both witnesses expressed their belief that Tiu would be a good Filipino citizen.

Legal Requirements for Naturalization

The Revised Naturalization Law, specifically Section 9, mandates that a petition for naturalization must be publicly posted to allow community members to voice any objections. The court noted that no evidence was presented proving compliance with this posting requirement, which is crucial for public transparency and the related interests of citizenship applications.

Government's Opposition and Economic Stability

The government contended that Tiu lacked a lucrative occupation, which is necessary for economic stability. Tiu's declared income, when combined with his wife’s, amounted to P6,660.00. The government argued that such an income is inadequate considering Tiu’s responsibilities to support his large family, especially with respect to the cost of living and the education of his children. The court reiterated concerns that Tiu's income might not provide for a decent living, potentially classifying him as a public charge.

Credibility of Witnesses

The court expressed doubt regarding the credibility of Tiu's witnesses, suggesting that they did

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