Sy v. Republic
REITERATIONFacts
1. The Antecedents: The petitioner, Susano Sy, filed a petition for naturalization. The Republic of the Philippines opposed. 2. Procedural History: The Court of First Instance of Negros Oriental granted for naturalization. 3. The Petition: The Republic of the Philippines appealed the decision of the Court of First Instance, maintaining that petitioner did not possess all the qualifications required by law.
Issue(s)
Whether the petitioner, Susano Sy, possesses a "lucrative" trade or occupation as required by law for naturalization.
Ruling
The Supreme Court reversed the appealed decision, denying the petitioner's application for naturalization. Costs were against the petitioner.
Ratio Decidendi
On the issue of "lucrative" trade or occupation: The Court held that the petitioner, Susano Sy, did not possess a "lucrative" trade or occupation. For the years preceding his petition (1958, 1959, 1960, and 1961), Susano Sy's average annual income was only P3,000.00. The Court cited its recent rulings in Uy vs. Republic (L-20208, June 30, 1965) and Uy vs. Republic (L-20799, November 29, 1965). In the first cited case, an applicant with an income of P3,600 per annum, though unmarried, was found not to have a "lucrative" occupation. In the second cited case, an applicant earning P250.00 per month was also deemed not to have a "lucrative" income. Based on these precedents, the Court concluded that an average annual income of P3,000.00 was insufficient to meet the "lucrative" requirement for naturalization. Therefore, without needing to consider other objections raised by the Solicitor General, the Court reversed the decision of the lower court.
Main Doctrine
An applicant for naturalization must possess a "lucrative" trade or occupation, which is determined by the sufficiency of income based on prevailing jurisprudence. An average annual income of P3,000.00 for the years preceding the petition was deemed insufficient to qualify as "lucrative."