G.R. No. L-14214; May 25, 1960
Richard Velasco, petitioner-appellant, vs. Republic of the Philippines, oppositor-appellee.

FACTS

Petitioner Richard Velasco filed a petition for naturalization before the Court of First Instance of Manila. He was born in the Philippines on May 12, 1932, to parents who became naturalized Filipino citizens in 1956. He claimed continuous residence in Manila, completion of his education (elementary, high school, and a dentistry degree from the University of the East in 1954), and that he remained a citizen of the Republic of China (Formosa) as he did not follow his father’s naturalization, being 23 years old at the time. He is single, engaged to a Filipino, employed at Wilson Drug Store since February 1957 with a monthly salary of P150, and previously worked as a salesman for his father. He professes knowledge of English and Tagalog, is a Catholic, has no criminal record involving moral turpitude, rejects polygamy and anarchy, and claims cash savings and stock investments. His moral character was attested by two witnesses: Santiago Mariano, a police sergeant, and Mrs. Paz J. Eugenio, his prospective mother-in-law. The trial court denied the petition, citing: (1) inconsistencies in the name used in the petition and documents (Richard Velasco, Richard C. Velasco, Richard Chua Velasco) without evidence they refer to the same person; (2) the biased nature of one character witness (the prospective mother-in-law) and the fact both witnesses also testified for petitioner’s brother, indicating a limited circle of Filipino friends; and (3) petitioner’s income of P150 per month was deemed neither lucrative nor substantial given the high cost of living. The court also noted petitioner’s employment at Wilson Drug Store began only a month before filing the petition and that the store was partly owned by his mother, suggesting a token arrangement to meet legal requirements.

ISSUE

Whether the trial court correctly denied the petition for naturalization based on petitioner’s failure to meet the legal requirements, particularly concerning the consistency of his name, the credibility of his character witnesses, and the sufficiency of his income.

RULING

Yes, the trial court’s denial is affirmed. The Supreme Court agreed with the lower court’s findings. The inconsistencies in petitioner’s name across the petition and documentary evidence, without proof they refer to the same person, create doubt about his identity. The character testimony of Mrs. Paz J. Eugenio, as petitioner’s prospective mother-in-law, is inherently biased, and the fact that both witnesses also testified for petitioner’s brother suggests a limited social integration with Filipinos. Most critically, petitioner’s income of P150 per month is neither lucrative nor substantial to satisfy the legal requirement for a viable income or occupation, especially considering his employment began barely a month before filing and appears to be a convenient arrangement with a family-owned business. Applying the principle that naturalization laws must be rigidly enforced and strictly construed in favor of the government and against the applicant, the Supreme Court held petitioner failed to qualify. The decision appealed from is affirmed, with costs against appellant.