Case Summary (G.R. No. L-17748)
Grounds for Petition
Manuel Yu's petition for naturalization was primarily denied on the basis that he was not engaged in a lucrative lawful occupation. Despite being of legal age and having continuously resided in the Philippines, the court found his earnings insufficient to qualify for naturalization under the prevailing laws.
Evidence of Residency and Character
The evidence presented by Yu supports his claim of continuous residence in the Philippines since childhood, highlighting his integration into Filipino society. He has demonstrated a belief in the principles of the Philippine Constitution, good moral character, and no affiliations that oppose or undermine organized government. Furthermore, he has not been charged with any crimes, nor does he suffer from any mental or contagious diseases.
Employment Status and Earnings
Yu claimed to earn an annual income of ₱1,440 as a sales representative for the Victory Steel Chair Factory owned by his mother. However, the court required more substantial proof of his employment status due to the potential conflict of interest arising from being employed by a family member. The court did not find the salary sufficient to qualify as lucrative, especially in light of the high cost of living and the low purchasing power of the currency at that time.
Additional Claims and Court’s Rationale
Yu attempted to contend that the free board and lodging provided by his mother should be considered part of his income, but the court noted that even when factoring this in, his total monthly income would not meet the threshold required for naturalization. Prior case law supported the notion that a minimum monthly income of ₱250 was necessary, with even lower amounts deemed insufficient for this purpose.
Conclusion and Affirmation of Ruling
The Court upheld the earlier decision of the Court
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Case Overview
- This case revolves around the appeal of Manuel Yu against the decision of the Court of First Instance of Manila, which denied his petition for naturalization as a citizen of the Philippines.
- The primary reason for the denial was the determination that Manuel Yu did not possess a lucrative lawful occupation.
Background of the Petitioner
- Manuel Yu was born on March 22, 1934, in Manila to Chinese parents and has continuously resided in the Philippines since birth, except for a brief childhood vacation to China.
- At the time of the trial, he was single and lived with his mother, who was a widow, at 1319 Soler Street, Manila.
- He is registered as a citizen of the Republic of China and holds the necessary documentation from the Bureau of Immigration, including an immigrant certificate of residence.
Education and Language Proficiency
- Yu completed his elementary education at the Chinese Republican School in Manila and attended high school at Quezon College.
- He pursued a semester of commerce at the Mapua Institute of Technology.
- He is proficient in both Tagalog and English, further demonstrating his integration into Filipino society.
Character and Conduct
- Yu has professed belief in the principles of the Philippine Constitution and has maintained a proper and irreproachable conduct throughout his residen