G.R. No. L-18550; February 28, 1964
IN THE MATTER OF THE PETITION OF ALBERT ONG LING CHUAN TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, ALBERT ONG LING CHUAN, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Albert Ong Ling Chuan, a native-born Chinese, petitioned for naturalization. The Court of First Instance of Manila granted his petition, finding he possessed all qualifications and none of the disqualifications under the law. The evidence showed he was single, employed as a stock clerk with an annual salary of P2,400, and had continuously resided in the Philippines since his birth in 1938. He presented clearances from various government agencies and three character witnesses: Pedro del Mundo, Domingo Cabatingan, and Atty. Apolonio Gonzales. These witnesses testified to petitioner’s good moral character and affirmed he had all the necessary qualifications.
The Republic appealed, contending the trial court erred in finding the character witnesses credible, in holding petitioner had a lucrative occupation, and in granting the petition.

ISSUE

The primary issues were: (1) whether petitioner presented credible character witnesses as required by law, and (2) whether petitioner had a lucrative occupation.

RULING

The Supreme Court reversed the lower court’s decision and denied the petition. On the first issue, the Court held that the character witnesses failed to meet the legal standard of credibility. The law requires witnesses to be “credible,” meaning they must have a good standing in the community, be trustworthy, reliable, and able to act as insurers of the applicant’s character. Here, the witnesses’ testimonies were found biased and unreliable due to their close personal or financial ties to petitioner’s father. Del Mundo’s acquaintance was casual and intermittent. Cabatingan, an illiterate, admitted he did not know the legal qualifications for citizenship, yet claimed petitioner possessed them all; his testimony about his business finances was also deemed suspect. Atty. Gonzales, the family lawyer, lacked the necessary detachment. These circumstances rendered them unqualified to vouch for petitioner’s character.
On the second issue, the Court ruled that petitioner’s employment did not constitute a lucrative occupation. His monthly salary of P200 (P2,400 annually) was deemed insufficient, considering the low buying power of the peso, to support himself independently, as he was single and still receiving support from his father. Naturalization is a privilege, and the burden is on the applicant to prove strict compliance with all legal requirements. Petitioner’s failure to present credible character witnesses and to demonstrate a lucrative income warranted the denial of his application. The decision was reversed.