Go v. Republic
REITERATIONFacts
1. The Antecedents: Lorenzo Go, also known as Lorenzo Chua, filed a petition for naturalization. The Republic of the Philippines opposed the petition, primarily due to the petitioner's stated monthly income of P150.00, which was deemed insufficient under the Naturalization Law. 2. Procedural History: The petitioner filed his naturalization petition with the Court of First Instance (CFI) of Misamis Occidental on November 16, 1960. After trial, the CFI rendered a judgment in favor of the petitioner, declaring him entitled to acquire Philippine citizenship. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court. 3. The Petition: The appeal to the Supreme Court was based on two main arguments: (1) the petitioner's income of P150.00 per month was not considered lucrative by Supreme Court standards, and (2) the petitioner failed to adequately demonstrate his ability to speak and write one of the principal Philippine languages, a requirement for naturalization. The Supreme Court reversed the lower court's decision, finding the petitioner unqualified.
Issue(s)
Whether the petitioner's income of P150.00 per month is considered lucrative under the Naturalization Law. Whether the petitioner's ability to speak and write English and a principal Philippine language was sufficiently proven.
Ruling
The decision of the lower court is reversed. The petitioner is declared not qualified to acquire Philippine citizenship under the circumstances appearing on record. Costs are against the petitioner-appellee.
Ratio Decidendi
On the issue of lucrative income: The Supreme Court reiterated its consistent holding that P150.00 earnings per month for an unmarried applicant, who was both a student and a salesman, is not lucrative and substantial within the contemplation of the Naturalization Law. This is considering the prevailing high cost of living and the low purchasing power of the peso. The Court cited previous rulings, including one where P250.00 per month was deemed insufficient. Therefore, on this ground alone, the lower court's decision could not be sustained. On the issue of language proficiency: The Court found that the records did not show that the petitioner, although able to speak and write English, could also speak and write any of the principal dialects of the country. No questions in any of the dialects were propounded to him in court to demonstrate his knowledge. The Court emphasized that it cannot presume such ability in the absence of proof. It is incumbent upon applicants to prove all qualifications, and failure to do so leads to the assumption of contrariwise.
Main Doctrine
An income of P150.00 per month for an unmarried applicant, who is a student and salesman, is not considered lucrative within the meaning of the Naturalization Law, considering the cost of living and the low purchasing power of the peso. Furthermore, the ability to speak and write a principal Philippine language must be proven by actual demonstration in court.