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: (1) the petition was heard before the expiration of the 90-day period from the last publication of the notice; (2) petitioner lacked permission from his government to renounce his Chinese nationality; and (3) petitioner does 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 prior jurisprudence. However, the third ground was sustained. The Court found that while petitioner speaks a little English and writes Tagalog, he admitted he does not write English and does not speak or write Spanish. This failure to write English or Spanish means he does not fully satisfy the mandatory requirement under paragraph 5, section 2 of the Revised Naturalization Law. The Court rejected the contention that the adoption of Tagalog as an official language abrogated the English requirement, noting that English and Spanish remain official languages under the Constitution until otherwise provided by law. Compliance with the statutory language requirement is rigidly enforced as a condition for naturalization.

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