G.R. No. L-3353 December 29, 1950
In the matter of the petition of Benjamin Bautista (alias Ban Siong) to be admitted a citizen of the Philippines. BENJAMIN BAUTISTA, petitioner-appellee, vs. THE REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Benjamin Bautista (alias Ban Siong), a citizen of China, filed a petition for naturalization in the Court of First Instance of Manila. The court granted his petition. The Republic of the Philippines appealed, arguing that the petition was heard before the expiration of the 90-day period from the last publication of notice, that the petitioner lacked permission from his government to renounce his Chinese nationality, and that the petitioner did not write English.

ISSUE

Whether Benjamin Bautista possesses all the qualifications for naturalization, specifically the requirement under the Revised Naturalization Law to “speak and write English or Spanish and any of the principal Philippine languages.”

RULING

The Supreme Court reversed the lower court’s decision and denied the petition for naturalization. The first two grounds for appeal were deemed already overruled in previous jurisprudence. On the third ground, the Court found that the petitioner admitted he did not write English, and although he spoke a little English and could speak and write Tagalog, he did not speak or write Spanish. Therefore, he failed to fully comply with the statutory requirement to speak and write either English or Spanish, in addition to a principal Philippine language. The Court rejected the argument that the adoption of Tagalog as an official language abrogated the English requirement, noting that English and Spanish remained official languages under the Constitution. The law’s requirements are mandatory, and courts cannot modify them.

AI Generated by Armztrong.