Ong v. Republic
REITERATIONFacts
1. The Antecedents: Roberto Ong filed a petition for naturalization as a citizen of the Philippines. The Republic of the Philippines opposed the petition, asserting that Ong failed to meet the statutory requirements for citizenship. 2. Procedural History: The Court of First Instance of La Union rendered a decision finding Roberto Ong qualified for naturalization. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court. 3. The Petition: The Republic's appeal argues that Roberto Ong lacks the necessary qualifications for Philippine citizenship. Specifically, the appellant contends that Ong failed to prove he owns property worth P6,000, as alleged in his petition, and that he does not possess a lucrative trade, profession, or lawful occupation. The Court noted inconsistencies in Ong's claims regarding his employment and income, and the lack of credible evidence for his alleged property ownership.
Issue(s)
Whether the applicant possesses a lucrative trade or profession. Whether the applicant possesses property worth P6,000.00.
Ruling
The judgment of the Court of First Instance is reversed, and the petition for naturalization is dismissed. Costs are against the petitioner-appellee.
Ratio Decidendi
On the issue of lucrative trade or profession: The Court found the applicant's claim of being a salesman earning P130.00 monthly to be unsubstantiated and contradictory. His graduation in March 1958 and enrollment in Manila for the first semester of the school year 1958-1959 conflicted with his alleged employment since April 1958. Furthermore, his sister's unsworn statement regarding his salary was considered hearsay and flimsy. The Court reiterated its established jurisprudence that an applicant earning less than P250.00 per month is not considered to possess a lucrative trade or profession due to the high cost of living, citing previous cases. On the issue of property ownership: The Court found no credible evidence to support the applicant's claim of owning real property worth P6,000.00. His testimony alone was insufficient. The property mentioned was likely the family home, and he failed to present tax declarations or receipts in his name, nor explain its acquisition. The Revised Naturalization Law requires proof of property of a substantial amount, which was not met.
Main Doctrine
An applicant for naturalization must prove possession of a lucrative trade or profession and ownership of property of substantial amount, as required by the Revised Naturalization Law. Failure to substantiate these claims with credible evidence warrants dismissal of the petition.