G.R. No. L-17118, November 17, 1964
IN RE PETITION FOR ACQUISITION OF PHILIPPINE CITIZENSHIP, UY ENG HIOK, alias FORTUNATO UY, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

Petitioner-appellant Uy Eng Hiok, also known as Fortunato Uy, was born in Amoy, China on September 2, 1934. He arrived in the Philippines on January 8, 1938, and has since resided in Dalaguete, Cebu, where he was baptized as a Roman Catholic. He completed his primary and intermediate education at Dalaguete Elementary School and reached second-year high school at Anunciacion Institute in the same town. He is single and claimed to work as an associate and agent in his father’s general merchandise, lumber, and copra business, receiving a monthly salary of P140.00. He filed a petition for naturalization, which was denied by the Court of First Instance of Cebu. The trial court found multiple deficiencies in his petition and evidence. Uy Eng Hiok appealed, challenging the lower court’s findings.

ISSUE

Whether the Court of First Instance of Cebu correctly denied the petition for naturalization of Uy Eng Hiok.

RULING

Yes, the Supreme Court affirmed the denial of the petition. The Court held that the petitioner failed to meet the stringent requirements for naturalization under Commonwealth Act No. 473 , as amended (The Revised Naturalization Law). The decision was based on several grounds, with the most decisive being the petitioner’s failure to prove he had a lucrative occupation, a mandatory qualification.
1. Lack of Lucrative Occupation: The petitioner’s claimed monthly income of P140.00 was deemed insufficient to constitute a “lucrative occupation” as required by law. The Court, citing recent jurisprudence, noted that even higher monthly salaries (e.g., P200.00) were inadequate due to the low purchasing power of the Philippine peso. Furthermore, the evidence of his employment was unsatisfactory. It relied solely on his own testimony and the hearsay statements of his witnesses. His failure to present the business payroll, as requested by the trial court, despite claiming to be an employee of his father’s business, weakened his claim.
2. Burden of Proof Not Satisfied: The Court reiterated that in naturalization cases, the applicant bears the burden of proving by competent and satisfactory evidence that he possesses all qualifications and none of the disqualifications under the law. The petitioner failed to discharge this burden.
3. Additional Grounds for Denial: The Supreme Court also cited other deficiencies that justified the denial, even if not all were extensively discussed, as the issue of income was dispositive. These included:
* Failure to attach his certificate of arrival to his declaration of intention, as required by the 1939 Rules and Regulations of the Department of Justice.
* The trial court’s express finding, based on having observed him testify, that he did not possess sufficient knowledge of the English language.
Absence of evidence showing that his petition was duly published in the Official Gazette.
His use of an alias (“Hioga”) without proof that it was an authorized exception under the Anti-Alias Law ( Commonwealth Act No. 142 ).
Therefore, the Supreme Court affirmed the judgment of the Court of First Instance of Cebu denying the petition for naturalization, with costs against the petitioner-appellant.