Lao v. Republic
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the naturalization of Francisco Lao, who sought to become a Filipino citizen. The Republic of the Philippines opposed his petition, raising issues regarding his moral character, the lucrativeness of his trade, and the proof of filiation of his children. 2. Procedural History: Francisco Lao filed a petition for naturalization in the Court of First Instance of Leyte on April 22, 1958, which was later amended on June 21, 1958. After a hearing, the court granted his petition on March 2, 1959. The government appealed this decision to the Supreme Court. 3. The Petition: The government's appeal, filed under Rule 45, argues that the trial court erred in finding that petitioner conducted himself in a proper and irreproachable manner, lacked good moral character, did not have a lucrative trade, and failed to properly prove the filiation of his children. The Supreme Court noted that Lao cohabited with Josefina Cawaling for nearly twelve years before marrying her four days prior to filing his petition, and that his annual income of P1,200 as a merchant was not lucrative, thus disqualifying him from naturalization.
Issue(s)
Whether the petitioner demonstrated good moral character and irreproachable conduct. Whether the petitioner possessed a lucrative trade or profession. Whether the filiation of the petitioner's alleged children was proven by competent evidence.
Ruling
The Supreme Court reversed the decision of the Court of First Instance, denying the petition for naturalization. The Court found that the petitioner lacked good moral character due to his cohabitation with his partner for nearly twelve years without the benefit of marriage, and that his income was not lucrative.
Ratio Decidendi
On Issue 1: The Court held that the petitioner did not possess good moral character and irreproachable conduct. This was based on the fact that he had five children born out of wedlock with Josefina Cawaling, whom he married only four days before filing his naturalization petition. Their common-law relationship, spanning almost twelve years, was deemed to demonstrate a lack of the required moral uprightness for naturalization. On Issue 2: The Court found that the petitioner's annual income of P1,200 as a merchant since 1950 was not lucrative. This income level, when considered in conjunction with his obligations and the nature of his conduct, was insufficient to meet the legal requirement of having a lucrative trade or profession for naturalization. On Issue 3: Due to the findings on the first two issues, the Court deemed it unnecessary to pass upon the third assigned error concerning the proof of filiation of the petitioner's alleged children. The denial of the petition was sufficiently established by the lack of good moral character and a lucrative trade.
Main Doctrine
The Court reiterated that an applicant for naturalization must demonstrate good moral character and possess a lucrative trade or profession. The case specifically found that the petitioner's cohabitation with his partner for nearly twelve years without the benefit of marriage, despite later marrying her, demonstrated a lack of good moral character. Additionally, his annual income of P1,200 as a merchant was deemed not lucrative enough to qualify him for naturalization.