G.R. No. L-20866. January 30, 1971.
IN THE MATTER OF THE PETITION OF LORETO LEE ONG TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. LORETO LEE ONG, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

Loreto Lee Ong, a Chinese citizen born in Naga City, filed a petition for naturalization. He presented evidence of his qualifications, including continuous residence, ability to speak English and the local dialect, belief in constitutional principles, and good moral character. To prove a lucrative trade or profession, a statutory requirement, Ong claimed he was the Assistant Manager and Paymaster of Venancio Hardware, owned by his brother, with a monthly salary of P200. He also submitted Income Tax Returns from 1952 to 1960 showing declared net incomes ranging from P1,885.84 to P4,148.60.
The Court of First Instance of Camarines Sur denied the petition. The trial court found issues regarding the truthfulness of Ong’s income tax declarations, particularly concerning fraudulent dependency exemptions. Ong appealed, assigning several errors focused on the court’s assessment of his tax returns.

ISSUE

Whether the petitioner-appellant, Loreto Lee Ong, has successfully proven that he has a lucrative trade or profession, a mandatory requirement for naturalization.

RULING

The Supreme Court affirmed the denial of the petition. The Court found it unnecessary to resolve the specific assignments of error regarding the alleged falsities in the income tax returns. Instead, the decision rested on the insufficiency of Ong’s evidence regarding his lucrative employment.
The Court expressed skepticism towards claims of employment in a family-owned business, noting such evidence is often presented as an easy but dubious method to meet the lucrative income requirement. The evidence for Ong’s employment as an assistant manager was deemed not entirely free from doubt and therefore not convincing. Even assuming the employment was genuine, his monthly salary of P200 in 1960 did not meet the judicial standard for a “lucrative occupation” considering the prevailing cost of living. Furthermore, the declared net incomes in his tax returns, which were significantly higher than what his salary alone would generate, were inconsistent. With no evidence of other income sources, this discrepancy rendered his claim of a stable financial capacity unreliable. Consequently, Ong failed to discharge the burden of proving he had a lucrative trade or profession, a fundamental qualification for Philippine citizenship. The appealed decision was affirmed.