G.R. No. L-20149; September 29, 1966
IN THE MATTER OF THE PETITION OF MANUEL SPIRIG LIM TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. MANUEL SPIRIG LIM, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Petitioner Manuel Spirig Lim obtained a judgment on April 4, 1959, granting his petition for naturalization filed on May 2, 1958. Two years later, he filed a petition to take his oath of allegiance. The Republic opposed, arguing that Lim did not have lucrative employment and lacked sufficient knowledge of the Philippine Government and Constitution. After a hearing, the Court of First Instance of Zamboanga City, on March 24, 1962, found Lim compliant with Republic Act 530 and authorized his oath-taking. On April 14, 1962, twenty-one days after the order and before it became final, Judge Gregorio D. Montejo administered the oath to Lim. The Republic appealed on the same day. The evidence showed Lim was single, an engineering student in Manila, and employed as a purchasing agent for Goodly Commercial Company and Sin Ho Commercial in Zamboanga City. His monthly salary was P150.00 at the time of his naturalization petition and P250.00 at the time of his oath-taking petition. Sin Ho Commercial was owned and managed by his father. During the hearing on June 10, 1961, Lim admitted ignorance about the essentials of Philippine Government and the Constitution, prompting the court to remark he did not deserve to be a citizen. The case was postponed. At a subsequent hearing on March 17, 1962, Lim recited the Constitution’s preamble and provisions verbatim, admitting he learned them after the previous hearing when the fiscal objected.

ISSUE

Whether the Court of First Instance erred in authorizing the oath-taking of Manuel Spirig Lim as a naturalized Filipino citizen.

RULING

The Supreme Court reversed the appealed order. It held that Lim’s claimed income was dubious and not lucrative, as his salary from Goodly Commercial Company (P150.00 monthly) was insufficient, and the increase from his father’s company appeared adjusted for naturalization purposes. The income qualification must be determined as of the date the application was filed. Furthermore, the oath-taking on April 14, 1962, was premature and an attempt to render the government’s right to appeal nugatory, as the order authorizing it was not yet final. Most critically, Lim’s belief in the principles underlying the Philippine Constitution was non-existent and insincere at the time of his application, as evidenced by his initial ignorance and subsequent memorization for the later hearing. The trial court’s act of re-trying the case after initially finding him unqualified was irregular and disapproved. The appealed order, the oath administered, the certificate of citizenship, and its registration were cancelled and declared null and void. Costs were imposed on Lim.