G.R. No. L-20490 June 29, 1968
IN THE MATTER OF THE PETITION OF RAMON CU KING NAN, alias CHUA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. RAMON CU KING NAN, alias CHUA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

On September 5, 1960, Ramon Cu King Nan, alias Chua, filed a petition for naturalization with the Court of First Instance of Nueva Ecija. He alleged he was born in China on January 21, 1919, arrived in the Philippines on April 18, 1935, and was a resident of San Jose, Nueva Ecija, with a former residence in Muñoz, Nueva Ecija. He was married to Ines Arellano Chua and had eight children. He was engaged in the lumber business with an average annual income of P8,000 to P9,000, had resided continuously in the Philippines for 26 years, spoke and wrote Tagalog and English, had enrolled his children in various schools, filed a declaration of intention, believed in Philippine constitutional principles, and conducted himself properly. The petition was supported by a joint affidavit of two character witnesses, Eulogio Santa Maria and Simplicio Andres. After publication and hearing, the lower court granted the petition on July 31, 1962. The Republic appealed.

ISSUE

Whether the lower court erred in granting the petition for naturalization.

RULING

The Supreme Court reversed the lower court’s decision and denied the petition. The Court found multiple fatal defects:
1. Insufficient Character Witnesses: The testimonies of the two character witnesses were too general and based on only occasional association with the petitioner. They failed to reliably establish the petitioner’s irreproachable conduct during his entire residence in the Philippines.
2. Non-compliance with Educational Requirement: The petitioner failed to prove that his children of school age were enrolled in schools where Philippine history, government, and civics were taught, as required by law. The evidence did not show where his eldest sons studied their primary and secondary courses, and there was no evidence that the Grace Christian High School taught the required subjects.
3. Failure to Prove Marriage: The petitioner did not satisfactorily prove his marriage to Ines Arellano Chua. The marriage certificate was not presented, and no evidence was offered to account for its absence. His own testimony and an entry in his alien certificate of registration were insufficient to establish a legal marriage.
4. Defective Publication of Notice: The published notice of hearing omitted the petitioner’s former place of residence (Muñoz, Nueva Ecija), which is a fatal defect as the publication is intended to solicit information from all places where the petitioner has resided.
5. Insufficient and Questionable Income: The petitioner’s declared average annual income of P8,000 to P9,000 at the time of filing was insufficient to support his wife and eight children. Furthermore, the higher income figures in his income tax returns for 1958-1960 were unreliable as they largely came from business enterprises not owned by him, and a discrepancy with his 1961 residence certificate cast doubt on the integrity of the returns and the petitioner’s moral character. The Court suspected the income was inflated for the purpose of the petition.