GR L 18009; (December, 1963) (Digest)

G.R. No. L-18009, December 27, 1963
Nicolas Loo Tee, petitioner-appellee, vs. Republic of the Philippines, oppositor-appellant.

FACTS

Nicolas Loo Tee filed a petition for naturalization in the Court of First Instance of Batangas, which was granted. The Republic appealed, opposing the grant on two principal grounds. First, the government contended that Loo Tee failed to conduct himself in a proper and irreproachable manner. This allegation stemmed from two fires that destroyed his insured properties: a warehouse in 1957 and a store in 1958. An investigating agent from the Constabulary testified that Loo Tee was evasive during the inquiry and opined that the burnings were intentional. Although no criminal charges were filed, the government argued the circumstances cast doubt on his moral character.
Second, the government challenged whether Loo Tee possessed a lucrative trade or occupation, a statutory requirement. The record contained his income tax returns for the years 1957, 1958, and 1959. For 1957, he reported a net income of P1,107.87, and for 1959, P2,693.96. He claimed an inability to ascertain his 1958 income due to the fire destroying his records. Loo Tee supported a wife and seven children, four of whom were attending school.

ISSUE

The core issues were: (1) whether petitioner conducted himself in a proper and irreproachable manner, and (2) whether he had a lucrative trade or occupation to support his family.

RULING

The Supreme Court reversed the lower court’s decision and dismissed the petition. On the first issue, the Court found that the absence of criminal prosecution did not automatically equate to irreproachable conduct. The burden of proving this positive qualification rests squarely on the applicant. The suspicious circumstances surrounding the fires, coupled with the investigative agent’s testimony regarding evasiveness, created sufficient doubt that Loo Tee had met this burden of demonstrating proper and irreproachable behavior in his community relations.
On the decisive second issue, the Court held that the reported incomes were not lucrative. Applying established jurisprudence, the Court ruled that an income must be substantial enough to provide adequate support for the applicant’s dependents. The meager net incomes of P1,107.87 and P2,693.96 for 1957 and 1959, respectively, were plainly insufficient to support a family of nine, including four school-going children. His inability to account for his 1958 income further undermined his financial claim. Consequently, Loo Tee failed to prove the statutory requirement of a lucrative trade or occupation, which alone warranted denial of his petition.