G.R. No. L-17055; October 27, 1961
MANUEL LAO, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Manuel Lao, a Chinese citizen born in Maasin, Leyte, filed a petition for naturalization before the Court of First Instance of Leyte. He presented evidence of his birth and continuous residence in the Philippines, his occupation as a merchant with an annual income of P1,500, and his high school education at Maasin Institute. The trial court granted his petition despite opposition from the provincial fiscal, prompting the Republic to appeal.
The record revealed that Lao had four children with Iluminada Lora, born between 1952 and 1957. However, he only married Lora in a civil ceremony on April 18, 1958, merely four days before filing his naturalization petition. At the time of the hearing, the children were not yet enrolled in school due to their age. The lower court found that Lao could speak and write English and the Cebuano-Visayan dialect, the latter based solely on his birth and continuous residence in Leyte.

ISSUE

The primary issues were: (1) whether the petitioner sufficiently proved his qualification to speak and write a principal Philippine dialect, and (2) whether he possessed the requisite moral character given his cohabitation and having children out of wedlock.

RULING

The Supreme Court reversed the lower court’s decision, denying the petition for naturalization. On the first issue, the Court held that the trial court’s finding regarding Lao’s knowledge of the Cebuano-Visayan dialect was an unwarranted presumption. The legal requirement under the Naturalization Law is that an applicant must establish by clear evidence, not mere presumption, the ability to speak and write either English, Spanish, or a principal Philippine dialect. The Court emphasized that continuous residence in a locality does not automatically equate to proficiency in its dialect, and the record was completely devoid of any evidence that Lao could speak or write Cebuano-Visayan.
On the second issue, the Court ruled that Lao failed to demonstrate proper and irreproachable conduct. His act of cohabiting with a woman and fathering four children over several years without the benefit of marriage, only formalizing the union days before his application, was conduct inconsistent with the moral standards of Philippine society. The Court stated that such behavior, while perhaps not penalized by civil law, runs counter to the prevailing customs and moral ideals of the country. This deficiency alone constituted a valid ground for disqualification. Consequently, the petitioner failed to meet the stringent qualifications for naturalization.