G.R. No. L-1761; August 24, 1949
In the matter of the petition for Philippine citizenship JOSE LEELIN, petitioner-appellee, vs. THE REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Jose Leelin, born in Tigaon, Camarines Sur to a Filipino mother and a Chinese father, petitioned for naturalization as a Filipino citizen. The Court of First Instance of Camarines Sur granted his petition. The Republic appealed, arguing that Leelin failed to satisfactorily prove his proficiency in English and a Philippine language and that he failed to establish that the laws of China grant Filipinos the right to become naturalized citizens thereof, a requirement for his own eligibility.

ISSUE

1. Whether the petitioner satisfactorily established his qualification of speaking and writing English and a principal Philippine language.
2. Whether the petitioner satisfactorily established that the laws of China grant Filipinos the right to become naturalized citizens thereof.

RULING

1. Yes. The Supreme Court held that Leelin’s positive testimony, coupled with his birth and lifelong residence in the Philippines, his Filipino mother, his education in Philippine schools, and his age, constituted more than satisfactory proof of his proficiency in English, Tagalog, and Bicol. The Court noted the government could have subjected him to a practical test if it doubted his claim.
2. Yes. The Court ruled that, following previous jurisprudence, a certified translation of the Chinese Naturalization Law from the Chinese Consulate General in Manila is sufficient evidence to establish that China permits Filipinos to become its citizens. Therefore, Leelin was not disqualified on this ground.
The decision of the lower court granting Leelin’s petition for naturalization was AFFIRMED.

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