G.R. No. L-13429; April 30, 1960
LUIS SANCHO alias GO GAM, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

Petitioner Luis Sancho, born in Amoy, China in 1907, arrived in the Philippines in 1919. He resided in various places, working as a cook, laborer, and “survey boy” until 1929. In 1930, he married Anselma Abengosa, a Filipina, with whom he had six children, all born in Sipocot, Camarines Sur. He claimed to be a merchant since 1938 with an average annual income of over ₱6,000 and to own a commercial building and lot in Sipocot worth more than ₱5,000. However, the only evidence submitted included his testimony, official receipts for business license fees in his wife’s name, and a 1955 joint income tax return showing a net income of ₱606.58. During the hearing, petitioner admitted he did not understand English and demonstrated an inability to write simple sentences in English or the Bicol dialect when tested by the trial court.

ISSUE

Whether petitioner possesses the qualifications for naturalization under Commonwealth Act No. 473 , specifically: (1) having a lucrative trade, profession, or lawful occupation; (2) owning real estate worth at least ₱5,000; and (3) knowing how to speak and write English or a principal Philippine language.

RULING

The Supreme Court affirmed the denial of the petition. Petitioner failed to prove he had a lucrative trade or occupation, as his evidence—limited testimony about past menial jobs and a meager joint income of ₱606.58 in 1955—was insufficient. He also failed to substantiate his claim of owning property worth over ₱5,000, as he presented no documentary evidence such as a tax declaration or deed. Most critically, petitioner did not meet the language requirement; he admitted he could not understand English and could not write in English or Bicol, despite being able to speak Bicol. Thus, he lacked the qualifications under Section 2 of the Naturalization Law. The decision of the lower court was affirmed, with costs against appellant.