GR L 17223; (June, 1964) (Digest)
G.R. No. L-17223, June 30, 1964
IN THE MATTER OF THE PETITION OF KOH CHET alias HIANCHIT S. CHUA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES; KOH CHET alias HIANCHIT S. CHUA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Koh Chet, born in Manila in 1934, petitioned for naturalization. He claimed continuous residence in the Philippines, except for two trips to China. He was a single fifth-year Chemical Engineering student at Far Eastern University and worked as a purchaser and salesman in his mother’s sari-sari store, earning a monthly salary of P200. He professed adherence to Philippine constitutional principles and had no criminal record or contagious disease. The Solicitor General opposed the grant, contesting the petitioner’s lucrative occupation and the credibility of his character witnesses.
The original petition stated he merely helped in the family store in return for support without a definite salary. This was later amended to allege the P200 monthly income. His witnesses, Carmen Basilio and Marcos Caroline, provided inconsistent testimonies on material facts, such as the circumstances of his father’s death. Furthermore, they admitted not having read the Constitution and did not attest to his proper and irreproachable conduct throughout his residence.
ISSUE
Whether the petitioner possessed the requisite qualifications for naturalization, specifically a lucrative occupation, and presented credible character witnesses.
RULING
The Supreme Court reversed the lower court’s decision and denied the petition. On the first ground, the Court found the petitioner failed to prove he had a lucrative occupation as required by law. His claimed monthly salary of P200, even if true, was deemed insufficient given the contemporary purchasing power of the currency, as established in prior jurisprudence like Ong Ling Chuan v. Republic. More critically, the veracity of this income was doubtful. The Court reasoned that a modest sari-sari store was unlikely to afford such a salary, and as a full-time engineering student, he could not have devoted substantial time to gainful employment there. The amendment from no salary to a P200 salary further undermined his claim’s credibility.
On the second ground, the Court found the character witnesses lacking in credibility and competence. Their inconsistent statements on significant matters, like the father’s death, indicated they did not know the petitioner intimately enough to vouch for his qualifications. Their admission of not having read the Constitution rendered them incapable of truthfully attesting to his adherence to its underlying principles. They also failed to declare his proper and irreproachable conduct during his entire stay. Consequently, the petitioner failed to meet the stringent statutory requirements for naturalization.
