Chiu v. Republic
REITERATIONFacts
The Antecedents: Petitioner, Chiu Bok alias David Chiu, an alien born in China, filed a declaration of intention to become a Philippine citizen on October 20, 1958, and a petition for naturalization on December 9, 1959. He arrived in the Philippines on June 30, 1930, resided in Manila and Cebu, and eventually settled in Dipolog, Zamboanga del Norte in 1936. He married Maria del Rosario Liong, with whom he has five children. His first four school-aged children attend government-recognized schools where Philippine Government, History, and Civics are taught. Petitioner speaks and writes English and Cebuano-Visayan. He operates a store named David Trading in Dipolog. Procedural History: The Court of First Instance of Zamboanga del Norte granted the application for naturalization. The Petition: The Solicitor General appealed the decision of the lower court.
Issue(s)
Whether the petitioner's income is lucrative enough to qualify him for naturalization. Whether the petitioner's use of an alias disqualifies him from naturalization.
Ruling
The decision granting Philippine Citizenship is hereby reversed, with costs against the petitioner-appellee.
Ratio Decidendi
On the issue of lucrative income: The Court held that the petitioner's income from his store, alleged to be around P5,000 and declining, is not lucrative enough to maintain a family. The Court cited previous rulings in Keng Giok v. Republic and Uy Ching No v. Republic, where incomes of P8,000 and P7,799.34, respectively, were deemed insufficient for families of similar size. The Court reasoned that the disparity in the cost of living between Manila and Zamboanga del Norte does not sufficiently bridge the P3,000 difference in income compared to the Keng Giok case. The Court reiterated that an alien must possess an income decent enough to maintain a family to be admitted to Philippine citizenship. On the issue of the use of an alias: The Court found that the petitioner's use of an alias, without authority, is a clear violation of Commonwealth Act No. 142, the Anti-Alias Law. This violation demonstrates that the petitioner is not a person of irreproachable character, which is a prerequisite for naturalization. The Court cited Lim Bun v. Republic of the Philippines in support of this disqualification.
Main Doctrine
An alien's income must be lucrative enough to maintain a family, and the use of an alias without authority is a violation of the Anti-Alias Law, disqualifying the alien from naturalization.