Yee v. Republic
REITERATIONFacts
1. The Antecedents: Petitioner Yee Bo Mann, born in Canton, China, in 1898 to naturalized U.S. citizens, immigrated to the Philippines in 1915. He has resided continuously in Cebu City since then, completing primary and secondary education, becoming a licensed public accountant in 1925, and engaging in business. He married Helen Leu, an American citizen, in 1922, and they have two children, Nellie and Philip. Petitioner expresses a strong desire to become a Filipino citizen, citing his long residence, education, friendships, and intention to spend his life in the Philippines. He believes in the Philippine Constitution, speaks English and Cebu Visayan, is not a polygamist, and has no criminal record. His sister is married to a Filipino. 2. Procedural History: The petitioner filed an application for naturalization. The Court of First Instance of Cebu granted the petition. The Republic of the Philippines, as the oppositor, appealed the decision to the Supreme Court. The appeal was based on two main grounds: the petitioner's alleged failure to declare his intention to become a Filipino citizen one year prior to filing the petition, and his failure to prove that Chinese law permits Filipinos to naturalize in China. 3. The Petition: This case is before the Supreme Court on appeal by the Republic of the Philippines. The appellant argues that the petitioner failed to comply with the Revised Naturalization Law by not declaring his intention to become a Filipino citizen one year before filing his application. Additionally, the appellant contends that the petitioner did not sufficiently prove that Chinese law allows for the naturalization of Filipinos in China. The Supreme Court, however, affirmed the lower court's decision, referencing prior rulings that enrollment in appropriate schools satisfies the educational requirement for exemption from the declaration of intention, and that the admissibility of the Chinese naturalization law translation was not a fatal flaw given previous judicial acceptance of the fact that China permits Filipino naturalization.
Issue(s)
Whether the petitioner complied with the requirement of declaring his intention to become a Filipino citizen one year before filing the petition. Whether the petitioner proved that the laws of China permit Filipinos to naturalize in that country.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance of Cebu, granting the petition for naturalization.
Ratio Decidendi
On the first issue (Declaration of Intention): The Court held that Section 6 of the Revised Naturalization Law exempts applicants who have resided continuously in the Philippines for 30 years or more from the requirement of declaring their intention one year prior to the application, provided they have given primary and secondary education to all their children in public or recognized private schools. The Court clarified its previous rulings, stating that enrollment in the proper school is sufficient compliance, even if the children have not yet completed their secondary education. Petitioner's children were studying in school, thus satisfying this requirement. On the second issue (Reciprocity of Naturalization Laws): The Court found no merit in the government's objection regarding the admissibility of the translated Chinese naturalization law. The Court stated that it has already accepted as a fact in previous naturalization cases that the laws of China permit Filipinos to naturalize in that country. Therefore, the requirement of reciprocity was deemed satisfied.
Main Doctrine
Enrollment in the proper school is sufficient compliance with the requirement that an applicant for naturalization must have given primary and secondary education to all his children in public or recognized private schools, even if they have not yet completed their secondary education. Furthermore, the Supreme Court may take judicial notice of the fact that Chinese laws permit Filipinos to naturalize in China.