Case Summary (G.R. No. L-10704)
Background Facts
Simeon Tan Lim, born on June 9, 1926, in Davao City to Chinese parents, filed a declaration of intention to become a Filipino citizen on January 22, 1954, prior to submitting his formal petition for naturalization on January 25, 1955. Lim presented witnesses Dr. Juan Belisario and Dr. Jose Ebro, both reputable residents of Davao, who testified to his good moral character. Throughout his life, aside from a brief period accompanying his brother in Shanghai from 1946 to 1948, Lim has resided continuously in the Philippines. He has a bachelor’s degree in Chemistry and demonstrated proficiency in English, Visayan, and Tagalog. Lim is the manager of Kwong Hoc Plantation Co., Inc. and had previously invested in the Davao Hardware Company.
Government's Opposition
The Government opposed Lim's application on various grounds, primarily questioning the credibility and qualifications of the character witnesses. The Fiscal contended that the character witnesses were not competent to testify on Lim's moral character and suggested that Lim failed to prove his allegiance to the principles underlying the Philippine Constitution. Furthermore, the opposition argued that the affidavits presented by the witnesses were insufficient due to vague assertions concerning the duration and nature of their acquaintance with Lim.
Court's Findings
The lower court found that both witnesses met the requirements of the Naturalization Law, stating they had known Lim since his childhood. Although the Government argued that the affidavits lacked specifics regarding the witnesses' knowledge of Lim's residency and character, the court concluded that their testimonies adequately established Lim’s qualifications. Dr. Belisario's declaration confirmed his acquaintance with Lim since birth, countering the Government’s claims of vagueness regarding the witness’s tenure and knowledge of Lim’s character.
Legal Analysis
The Court held that the lower court did not err in granting Lim's application for citizenship. It interpreted the affidavits collectively and affirmed that the assertion of Lim having all necessary qualifications implicitly included the absence of disqualifications under the Naturalization Law. The court did not f
...continue readingCase Syllabus (G.R. No. L-10704)
Case Introduction
- The case concerns the appeal by the Government against a decision made by the Court of First Instance of Davao, which granted Simeon Tan Lim's petition for Philippine citizenship.
- The decision was rendered on May 23, 1958, under G.R. No. L-10704.
Background Facts
- Simeon Tan Lim filed his declaration of intention to become a Filipino citizen on January 22, 1954, followed by his petition on January 25, 1955.
- The petition was published in the Official Gazette and a newspaper as required by law.
- Lim was born in Davao City on June 9, 1926, to Chinese parents and has lived in the Philippines continuously, except for a two-year period (1946-1948) when he accompanied his brother to Shanghai.
- He attended the Davao Chinese School and later graduated with a Bachelor of Science in Chemistry from Adamson University.
- Lim has been involved in the community and has a good command of English, as well as working knowledge of Visayan and Tagalog dialects.
- He served as manager of Kwong Hoc Plantation Co., Inc., earning a monthly salary of P200.00, and was previously a stockholder of the Davao Hardware Company.
Evidence Presented
- Lim prese