GR L 17054; (November, 1962) (Digest)
G.R. No. L-17054; November 29, 1962
FRANCISCO LAO alias ME-O, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, opponent-appellant.
FACTS
Francisco Lao filed a verified petition for naturalization in the Court of First Instance of Leyte. After a hearing, the court granted his petition and entered a decree declaring him qualified to become a Filipino citizen by naturalization. The Republic of the Philippines appealed the decision, assigning three specific errors.
The government contended that the trial court erred in finding that Lao conducted himself in a proper and irreproachable manner, as he lacked good moral character. It also argued that the court erred in not holding that Lao did not have a lucrative trade or profession, and in not finding that the filiation of his alleged children was not proved by competent evidence.
ISSUE
The core issue is whether Francisco Lao possessed the qualifications for naturalization, specifically good moral character and a lucrative income, as required by law.
RULING
The Supreme Court reversed the decree of naturalization and denied Lao’s petition. The Court’s ruling was anchored on two fatal deficiencies that disqualified him under the naturalization law.
First, the Court found that Lao lacked the good moral character and proper and irreproachable conduct required of an applicant. The record established that he had five children with Josefina Cawaling, all born out of wedlock between 1949 and 1957. He married Cawaling only on April 18, 1958, a mere four days before filing his naturalization petition. This prolonged common-law relationship, spanning almost twelve years, demonstrated moral indifference to the legal and social institution of marriage. Such conduct was deemed inconsistent with the standard of good moral character mandated for prospective citizens.
Second, the Court held that Lao failed to prove possession of a lucrative trade, profession, or occupation. His stated annual income was only P1,200 as a merchant, which the Court explicitly declared as not lucrative. This finding on inadequate income, standing alone, was sufficient to disqualify him. When combined with his disqualifying moral character, it conclusively barred his naturalization. Given these dispositive grounds, the Supreme Court deemed it unnecessary to resolve the third assigned error regarding the proof of his children’s filiation. The petition was denied with costs against Lao.