G.R. No. L-16828; May 30, 1962
SI NE @ SI AN LOK, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Petitioner Si Ne, a Chinese citizen, filed a petition for naturalization before the Court of First Instance of Manila. He alleged continuous residence in the Philippines for over ten years, an average annual income of P3,500, the ability to speak English and Tagalog, and enrollment of his minor children in recognized schools. He further claimed to have all qualifications and none of the disqualifications under the Revised Naturalization Law. The petition was supported by affidavits from Remedios Gasel Vda. de Castelo, a bookkeeper, and Servando P. Patawaran, an accountant from the same company where petitioner worked. The trial court granted the petition.
The Republic appealed, contending that petitioner failed to establish the filiation of his children, did not meet all qualifications, and that his witnesses were not credible. The government highlighted inconsistencies in petitioner’s testimony regarding his trips abroad, which did not align with the birthdates of his children born in 1937, 1941, and 1945. It also pointed out that three of his children, who were of school age during the required ten-year residency period, remained in China and were not enrolled in Philippine schools.

ISSUE

Whether the trial court erred in granting the petition for naturalization.

RULING

Yes, the Supreme Court reversed the trial court’s decision. The legal logic centers on petitioner’s failure to satisfy three mandatory requirements under the Revised Naturalization Law. First, regarding the enrollment of children, the law requires an applicant to have enrolled all minor children of school age in recognized Philippine schools during the entire period of required residence. Petitioner lacked special qualifications, thus needing ten years of residence. During this period, three of his children—Si Meng (born 1931), Si Leng (born 1937), and Si Lee (born 1941)—were of school age but remained in China. Their absence from the Philippines did not excuse petitioner; it was his duty to bring them to comply with the educational mandate, a failure fatal to his application as established in prior jurisprudence.
Second, the affidavits of support did not meet the statutory standard. The law requires affidavits from at least two credible persons, meaning individuals of good standing, honesty, and reliability in the community, who act as insurers of the applicant’s character. Here, both affiants had close professional or business ties to petitioner: one was a bookkeeper for his cousin and had a husband who was his lawyer, and the other was a subordinate employee in his company. These relationships rendered them partial and not the disinterested, credible witnesses the law demands.
Third, petitioner’s inconsistent testimony about his travel history cast doubt on his overall credibility and the veracity of his declarations, particularly concerning the filiation of his children. Collectively, these deficiencies proved petitioner did not possess all qualifications prescribed by law. The petition was therefore correctly denied on appeal.