GR L 19112; (October, 1964) (Digest)
G.R. No. L-19112; October 30, 1964
IN THE MATTER OF THE PETITION OF TIO TEK CHAI alias SO LIM TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. TIO TEK CHAI ALIAS SO LIM, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Tio Tek Chai, born in China in 1921, arrived in the Philippines in 1923 and resided in Manila. He filed a petition for naturalization, which the Court of First Instance of Manila granted in 1961. The government appealed. The petitioner, a bakery owner married with five children, presented testimonial evidence from himself and character witnesses regarding his qualifications. A key fact revealed was his 1956 conviction for violating the Price Tag Law ( Republic Act No. 71 ), to which he pleaded guilty and paid a P10.00 fine. He explained that a storekeeper failed to replace a price tag, and he chose to plead guilty to avoid litigation, despite not being present at the time of the violation.
ISSUE
Whether the petitioner possesses all the qualifications, particularly the requirement of having conducted himself in a proper and irreproachable manner, to be granted Philippine citizenship.
RULING
The Supreme Court reversed the lower court’s decision and denied the petition. The legal logic centers on the affirmative qualifications required under Section 2 of the Revised Naturalization Law ( Commonwealth Act No. 473 ), not merely the absence of absolute disqualifications. The Court held that the petitioner’s conviction for violating the Price Tag Law demonstrated conduct that was not “proper and irreproachable” as required. The law protects the public from profiteering, and its violation, regardless of whether it involves moral turpitude, reflects poorly on one’s relationship with the constituted government. The Court gave little credence to his explanation, noting that a willingness to plead guilty merely to avoid court proceedings betrays a lack of faith in the justice system, which is unbecoming of a prospective citizen.
Furthermore, the Court, exercising its authority to review the entire record on appeal in naturalization cases, considered additional grounds not raised by the government. It noted two other minor convictions (for sanitation and illegal construction violations) and found the petitioner’s reported annual income of about P5,000.00 in 1959 insufficient to support his wife and five children, failing the requirement of a lucrative trade or profession. The cumulative effect of these findings—a pattern of minor legal violations and inadequate financial capacity—established that the petitioner did not meet the stringent qualifications for naturalization.