Co v. Republic
REITERATIONFacts
The Antecedents: Pedro Co, a Chinese citizen married to Anita Lim, filed a petition for naturalization. Procedural History: The Court of First Instance of Manila approved Pedro Co's petition for naturalization. The Appeal: The Republic of the Philippines, through the Solicitor General, appealed the decision of the lower court, questioning the sufficiency of Pedro Co's qualifications, specifically arguing that he did not possess a lucrative trade, profession, or occupation.
Issue(s)
Whether the petitioner-appellee, Pedro Co, possessed a lucrative trade, profession, or occupation sufficient to qualify for naturalization.
Ruling
The Supreme Court sustained the appeal, reversed the decision of the lower court, and denied the petition for naturalization.
Ratio Decidendi
On Issue 1: The Supreme Court held that Pedro Co did not possess a lucrative trade, profession, or occupation. It was admitted that for the three years preceding the hearing, his average annual income was only P2,320.00. The Court, in light of its previous decisions, deemed this income insufficient to be considered lucrative, particularly because the applicant was married and had a wife to support. The Court cited several prior cases where applicants with similar or even higher incomes were denied naturalization for lacking a lucrative occupation. Therefore, based on established jurisprudence, the petitioner's financial standing did not meet the statutory requirement for naturalization.
Main Doctrine
The Supreme Court reiterated that an applicant for naturalization must possess a lucrative trade, profession, or occupation. This requires an income that is more than what is necessary for subsistence and is substantial enough to support oneself and one's family. In this case, an average annual income of P2,320.00 was deemed insufficient to qualify as lucrative, especially considering the applicant was married and had a wife to support, aligning with previous rulings on similar income levels.