G.R. No. L-19695; October 31, 1964
IN THE MATTER OF THE PETITION OF MATEO QUINGA CHUA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, MATEO QUINGA CHUA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Petitioner Mateo Quinga Chua, born in the Philippines, filed a petition for naturalization. He alleged he was single, employed as a bookkeeper with an annual salary of P2,400 plus lodging allowances, and was conversant in English and Waray. He claimed to have received his education in schools teaching Philippine history and government, conducted himself properly, and mingled socially with Filipinos. The notice of hearing for his petition was published in the Official Gazette and the newspaper “La Nacion.” Two character witnesses testified on his behalf. The trial court found him qualified and granted the petition.
The Republic, through the Solicitor General, opposed and appealed. The opposition contended that petitioner failed to prove compliance with the mandatory posting of the notice of hearing in the Clerk of Court’s office, did not possess a lucrative income, and that his character witnesses lacked a reliable basis for their testimony. Petitioner admitted no evidence was presented regarding the physical posting but argued a presumption existed that the Clerk of Court performed this official duty.

ISSUE

Whether the trial court erred in granting the petition for naturalization despite alleged fatal defects in jurisdictional compliance and proof of qualifications.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the petition. The ruling was anchored on two principal grounds constituting fatal defects. First, the Court held that the mandatory requirement under the Revised Naturalization Law for the posting of the notice of hearing in a public and conspicuous place in the office of the Clerk of Court is jurisdictional. Citing Co v. Republic, the Court ruled that non-compliance with this requirement, which ensures proper notice to the public, affects the court’s very authority to hear the case. This defect is not cured by a mere presumption of regularity of official duty, especially when the law explicitly requires positive proof, nor by the failure to raise the objection at the trial level.
Second, the Court found petitioner failed to prove he had a lucrative trade, profession, or income. His claimed annual income of P2,400, even if true, was deemed insufficient given the high cost of living. This claim was further rendered doubtful because his income tax returns reported a lower net income. This discrepancy indicated either a false claim of income or a fraudulent tax return, both of which disqualify him from naturalization by demonstrating a lack of good moral character and failure to meet the financial qualification. Given these conclusive defects, the Court found it unnecessary to address the other issues raised by the Solicitor General.