G.R. No. L-23591; March 28, 1969
Leoncio Yu Lim, petitioner-appellee, vs. Republic of the Philippines, oppositor-appellant.

FACTS

Leoncio Yu Lim filed a petition for naturalization with the Court of First Instance of Surigao del Norte. He alleged he was single, born on October 23, 1931, in Surigao, Surigao del Norte, a general merchant and proprietor of Southern Bazar with an average annual income of P3,398.03, and a “co-owner” and assistant manager of Pan Pacific Remnant Industry, a partnership in Quezon City, from which he derived an annual salary of P1,440.00. The government opposed the petition. After trial, the court granted the naturalization. The Republic appealed, arguing insufficient income, unauthorized use of an alias, and lack of evidence of belief in constitutional principles.

ISSUE

Whether the trial court erred in granting Leoncio Yu Lim’s petition for naturalization.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the petition for naturalization. The Court sustained the oppositor-appellant on all grounds.
1. Insufficient Income: The petitioner’s claimed salary of P1,440.00 annually from Pan Pacific Remnant Industry was not corroborated by any witness or document and therefore could not be considered. The partnership was registered only in July 1962 and had declared no dividends. Furthermore, the petitioner resided in Surigao while the partnership’s office was in Quezon City, an inconsistency left unexplained. Excluding the unproven salary, his average annual income from his business was only P2,043.59 (averaging P172.00 monthly), which the Court deemed inadequate and not lucrative, citing prior rulings that even P300.00 a month was insufficient. The trial court’s computation erroneously treated a P1,800.00 income tax exemption as disposable income.
2. Unauthorized Use of Alias: The petitioner disclaimed “Dodong” as an alias, calling it a nickname. However, several official certificates he presented (Exhibits “N”, “O”, “S”, etc.) listed “Dodong” as an alias. No evidence showed this use was legally authorized, and the alias was not mentioned in his petition.
3. Lack of Evidence of Belief in Constitutional Principles: The petitioner and his witness merely asserted in court that he “believes in the principles of the Constitution” without providing any particulars or factual basis. The Court held that such naked statements, without supporting facts, are neither competent nor adequate proof of such belief. The burden of proof lies with the petitioner.