GR L 16184; (September,1961) (Digest)
G.R. No. L-16184; September 30, 1961
IN THE MATTER OF THE PETITION OF QUE CHOC GUI TO BE ADMITTED AS CITIZEN OF THE PHILIPPINES. QUE CHOC GUI, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Petitioner Que Choc Gui, born in the Philippines in 1937 to Chinese parents, applied for naturalization. He established continuous residence since birth and completed his education in local institutions. The Court of First Instance of Manila granted his petition. The Republic appealed, contesting the sufficiency of evidence regarding his qualifications and lack of disqualifications under the Naturalization Law ( Commonwealth Act No. 473 ).
The government’s opposition centered on procedural and substantive deficiencies in petitioner’s evidence. Specifically, it challenged the adequacy of the testimony provided by his two character witnesses, Eriberto Angeles and Adela Purugganan, whose affidavits were attached to the petition as required by law.
ISSUE
Whether the petitioner satisfactorily proved his qualifications and absence of disqualifications for naturalization through competent evidence, particularly the testimony of his character witnesses.
RULING
The Supreme Court reversed the lower court’s decision and dismissed the petition. The legal logic rests on strict compliance with statutory requirements for naturalization, particularly the evidentiary role of character witnesses. The Court, citing Ong vs. Republic, held that the two credible persons whose affidavits are attached to the petition must personally testify and confirm all requisite declarations. They must prove they are credible Philippine citizens who personally know the applicant and can attest to his specific qualifications, including residency, good moral character, belief in constitutional principles, and lack of any statutory disqualification.
Here, the witnesses’ testimony was fatally deficient. They failed to testify on crucial points, such as petitioner’s belief in constitutional principles or desire to embrace Filipino customs. Witness Angeles merely identified his affidavit and admitted his knowledge was limited to petitioner not having committed a crime. Witness Purugganan’s acquaintance was casual, stemming from shopping at his father’s store. Neither demonstrated sufficient personal knowledge to “vouch for” or “underwrite” the application as required. Furthermore, the Court found they did not meet the standard of “credible persons” within the meaning of the law, which requires individuals of good standing and repute in the community whose word serves as a reliable warranty. Additionally, petitioner’s claimed monthly income of P150 as a salesman in his father’s store was deemed insufficient to constitute a lucrative occupation under prevailing jurisprudence. Consequently, petitioner failed to discharge his burden of proof.
