Wong Kim Goon v. Republic
REITERATIONFacts
1. The Antecedents: Wong Kim Goon, a citizen of the Republic of China, arrived in the Philippines on May 29, 1918. He has resided in Bayombong, Nueva Vizcaya, where he studied up to grade VII. He is married and has six children, five of whom are dependent on him for support. Wong Kim Goon owns two stores and reported an average annual income of P6,000 from 1956 to 1960, with a lesser amount of P4,000 stated in his petition. 2. Procedural History: Wong Kim Goon filed a petition for naturalization on February 26, 1960. The Court of First Instance of Nueva Vizcaya granted his petition in a decision dated August 11, 1962. The Republic of the Philippines, as oppositor, appealed this decision to the Supreme Court. 3. The Petition: The Republic of the Philippines, as appellant, contests the lower court's decision granting Wong Kim Goon's naturalization. The primary argument, and the basis for the Supreme Court's reversal, is that the petitioner failed to demonstrate a lucrative trade, profession, or occupation as required by law. Citing previous rulings, the appellant contends that Wong Kim Goon's reported income is insufficient to support himself, his wife, and his six children, rendering his petition ineligible for naturalization.
Issue(s)
Whether the petitioner's annual income is lucrative enough to qualify for naturalization under Commonwealth Act No. 473.
Ruling
The judgment appealed from is reversed and the petition for naturalization is hereby denied, without costs.
Ratio Decidendi
On the issue of lucrative income: The Court held that the petitioner failed to meet the requirement of a lucrative trade, profession, or occupation as mandated by Section 2, Paragraph 4 of Commonwealth Act No. 473. The petitioner, who is married and has six children, five of whom are dependent on him, reported an annual income ranging from P4,000 to P6,000. This income was deemed insufficient to be considered lucrative, especially when compared to previous rulings of the Supreme Court. In Keng Giok v. Republic, an annual income of P8,687.50 was found not lucrative for a petitioner with a wife and five children. Similarly, in Tan v. Republic, an income of P6,800 per year was held not lucrative for a married applicant with one child. Given the petitioner's marital status and the number of dependents, his reported income clearly falls short of the standard for a lucrative livelihood necessary for naturalization. Consequently, the Court found it unnecessary to pass upon the other points raised by the appellant.
Main Doctrine
An annual income of P4,000 to P6,000 is not considered lucrative for a married applicant with six children, failing to meet the requirements for naturalization under Commonwealth Act No. 473.