Son v. Republica
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the naturalization of Jose Son, a Chinese-born individual residing in the Philippines. The government appeals a lower court's decision to grant naturalization, arguing that Jose Son failed to meet mandatory requirements. 2. Procedural History: Jose Son filed a petition for naturalization with the Court of First Instance of Sorsogon. The court granted the petition, decreeing his naturalization. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court. 3. The Petition: The government's appeal, filed under Rule 45, contends that the lower court erred in not finding that Jose Son failed to comply with the mandatory requirement of filing a declaration of intention to become a Filipino citizen with the Bureau of Justice one year prior to filing his petition. The government argues that Jose Son, born in the Philippines to Chinese parents and having only completed elementary education, does not fall under any exemptions to this rule, specifically the exemption for those born in the Philippines who have received primary and secondary education, or those with thirty years of continuous residence.
Issue(s)
Whether Jose Son is exempt from the requirement of filing a declaration of intention to become a Filipino citizen one year before filing his petition for naturalization. Whether speaking English is sufficient to qualify an alien for Philippine citizenship, even without completing secondary education.
Ruling
The petition for naturalization is dismissed with costs against the appellee.
Ratio Decidendi
On the issue of exemption from filing a declaration of intention: The Court held that Jose Son was not exempt from the requirement of filing a declaration of intention. Section 5 of the Naturalization Law (Commonwealth Act No. 473, as amended by Commonwealth Act No. 535) mandates that every applicant must file a sworn declaration of intention to become a Filipino citizen with the Office of Justice one year before filing the petition. Section 6 provides exemptions for those born in the Philippines who received their primary and secondary education in government or recognized schools, or those who have resided continuously in the Philippines for thirty years or more. Jose Son, despite being born in the Philippines, was only 23 years old and thus had not resided for thirty years. Furthermore, he had only completed elementary education, not primary and secondary education as required for exemption. Therefore, he was bound by the general rule to file the declaration of intention, which he failed to do. On the sufficiency of speaking English for citizenship: The Court rejected the applicant's argument that his ability to speak English, proven by testifying in that language, qualified him for citizenship. The Court reasoned that accepting this argument would set a dangerous precedent, allowing any foreigner who speaks English, regardless of their educational attainment, to claim equal rights. The Legislature considered secondary education indispensable for an alien seeking to become a Filipino citizen, encompassing not only the knowledge of English but also various subjects, principles of morality, democratic practices, and beliefs assimilated in school. This educational requirement is more than just linguistic proficiency.
Main Doctrine
A naturalization applicant born in the Philippines who has not resided therein for thirty years and has not received primary and secondary education in government or recognized schools is required to file a declaration of intention to become a Filipino citizen one year before filing the petition for naturalization.