G.R. No. L-30424. January 28, 1971. IN THE MATTER OF THE PETITION OF BENITO LIM TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. BENITO LIM, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.
FACTS:

Benito Lim, born on August 15, 1943, in Batangas, Batangas, to Chinese parents, filed a petition for naturalization. He was a lifelong resident of Batangas. He completed his primary and intermediate education at the Chinese Kipsi Memorial School and his secondary education at Golden Gate Colleges, graduating in 1960. He worked at the Batangas Grocery and Dry Goods Store, eventually becoming its manager with an annual income of P7,200. The petitioner asserted he possessed good moral character, believed in Philippine constitutional principles, was not affiliated with subversive groups, and had mingled socially with Filipinos as a member and director of the Batangas Lions Club. He also professed proficiency in English and Tagalog.
The Court of First Instance of Batangas denied his petition. On appeal, the Republic, through the Solicitor General, opposed the grant of citizenship. The Supreme Court focused its review on the petitioner’s compliance with specific statutory requirements for naturalization under Commonwealth Act No. 473 , as amended.

ISSUE

Whether the Court of First Instance correctly denied Benito Lim’s petition for naturalization.

RULING

Yes, the denial was correct. The Supreme Court affirmed the lower court’s decision, holding that the petitioner failed to comply with the mandatory requirements of Sections 5 and 6 of the Naturalization Law. The Court found that the Chinese Kipsi Memorial School, where Lim received his primary and intermediate education, was definitively a Chinese school. While the school was government-recognized and taught Philippine history and civics, there was no evidence presented that it was “regularly attended by a sizeable number of Filipino students from whom applicant could have imbibed Filipino customs and traditions.” Following established jurisprudence, such as Lee Ng Len vs. Republic, attendance at a Chinese school without a substantial Filipino student population disqualifies an applicant from the exemption to file a prior declaration of intention to become a citizen.
Consequently, Benito Lim was not exempt from filing said declaration. His failure to file this declaration constituted a fatal jurisdictional defect that rendered his entire naturalization proceeding null and void, as held in Sio Kim vs. Republic. Given this dispositive ground, the Supreme Court deemed it unnecessary to address the other issues raised in the appeal. The judgment denying the petition was affirmed, with costs against the petitioner.