To v. Republic
REITERATIONFacts
1. The Antecedents: Manuel To, also known as Manuel Toh, a citizen of the Republic of China, filed a petition for naturalization in the Philippines. He alleged to have been born in Cotabato, Cotabato, on June 6, 1937, and to have resided in Pasay City since 1955. He claimed to be single, fluent in English and Tagalog, and employed by Elite Textile Company with an average annual income of P3,600.00. He asserted that he possessed all the qualifications and none of the disqualifications for Philippine citizenship as stipulated in the Naturalization Law, including exemption from filing a declaration of intention due to his birth in the Philippines and completion of primary and secondary education in recognized schools. 2. Procedural History: The petition for naturalization was filed in the Court of First Instance of Rizal (Pasay City) on January 6, 1961. Following the required publication in the Official Gazette and a newspaper of general circulation, the trial court proceeded with the merits of the case. On January 9, 1962, the court rendered a judgment granting the petitioner's prayer to be admitted as a citizen of the Philippines. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court. 3. The Petition: The Republic of the Philippines, as the oppositor-appellant, submitted an appeal to the Supreme Court, arguing that the lower court erred in two key aspects. Firstly, it contended that the petitioner did not possess a lucrative occupation, as his stated annual income of P3,600.00 included a bonus, which should not be considered for naturalization purposes according to established jurisprudence. Secondly, the appellant argued that the two character witnesses presented by the petitioner had not sufficiently known him to attest to his irreproachable conduct throughout his entire period of residence in the Philippines, as required by law.
Issue(s)
Whether the petitioner possesses a lucrative occupation. Whether the character witnesses sufficiently knew the petitioner to attest to his irreproachable conduct.
Ruling
The judgment appealed from is reversed, and the petition is denied, with costs against the petitioner.
Ratio Decidendi
On the issue of lucrative occupation: The Court held that bonuses cannot be taken into consideration when determining if an applicant has a lucrative occupation, citing previous rulings that bonuses are indefinite and contingent. Petitioner's income tax return for 1961 showed P1,000.00 of his P3,600.00 annual income as a bonus. Therefore, his average annual income should be considered P2,600.00. This amount was deemed insufficient to be considered lucrative, considering the prevailing standard of living and the low purchasing power of money. The Court reiterated the definition of lucrative employment, which requires an income with an appreciable margin over expenses to provide for contingencies like unemployment or sickness, thus avoiding becoming a public charge. The Court also referenced a previous case where an unmarried man earning P300.00 a month plus an annual bonus of P1,000.00 was not considered to have a lucrative income. On the sufficiency of character witnesses: The Court found that the attesting witnesses, Atty. Florencio M. Mauleon and Mr. William C. Limos, did not sufficiently establish the petitioner's proper and irreproachable conduct during his entire period of residence. The witnesses admitted that their contact with the petitioner consisted of isolated meetings during vacation times, where they would spend only a day or two with him. Such occasional meetings were deemed insufficient to enable them to observe the petitioner's behavior, character, beliefs, social contacts, and associations. Consequently, they were not in a position to know whether the petitioner possessed the qualification of proper and irreproachable conduct throughout his entire residence in the Philippines, as required by law.
Main Doctrine
Bonuses cannot be considered in determining whether an applicant for naturalization has a lucrative occupation, as they are indefinite and contingent. Furthermore, occasional meetings are insufficient for character witnesses to attest to an applicant's proper and irreproachable conduct during their entire period of residence.