G.R. No. L-21400; May 31, 1966
IN THE MATTER OF THE PETITION OF WILLIAM CHUA SIONG HUA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. WILLIAM CHUA SIONG HUA, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

On July 19, 1960, the Court of First Instance of Manila granted the petition for naturalization of William Chua Siong Hua, finding he possessed all qualifications and no disqualifications. The Republic did not appeal. Two years later, on September 24, 1962, petitioner filed a motion to take his oath of allegiance as required by Republic Act No. 530 . The Republic opposed the motion on grounds that: (1) petitioner had no lucrative occupation; (2) he violated immigration rules by failing to register and secure a Certificate of Residence; and (3) he used the name “Chua Siong Hua” without judicial authority and made conflicting declarations about his date of birth, casting doubt on his identity. On April 19, 1963, the lower court disallowed the oath-taking, finding petitioner’s claimed monthly income of P250 from his employment at his father’s business, Globe Electrical Supply, to be simulated. The court noted the sudden increase in applicants’ incomes following Supreme Court pronouncements, that petitioner was only 19 and a student when he started with that salary, the business had limited capital, and petitioner turned over his remaining salary to his mother, indicating he was not a bona fide employee but a dependent son. Petitioner appealed.

ISSUE

Whether the lower court correctly denied petitioner’s motion to take the oath of allegiance and be admitted as a Filipino citizen.

RULING

The Supreme Court affirmed the lower court’s order denying the motion. The Court found petitioner’s claimed income to be unreal and simulated, following precedents that income from employment in a parent’s business is dubious. Even if true, the amount was inadequate considering the peso’s purchasing power. The Court also found petitioner clouded his own identity by using different names and giving conflicting dates of birth (November 1, 1938 in his petition, November 2, 1938 in testimony, and November 11, 1938 in residence certificates). Furthermore, petitioner failed to register and secure an alien certificate of residence in 1959, for which he was fined, constituting a ground for disqualification. The Court rejected petitioner’s excuses for these discrepancies and violations, such as blaming his father or citing “lapses in the human mind.” Petitioner’s behavior in claiming a simulated income and blaming his father for legal difficulties constituted improper conduct, making him unworthy of citizenship. The appealed order was affirmed.