G.R. No. L-26706 June 30, 1969
IN THE MATTER OF THE PETITION OF YU CHUAN baptized as MACARIO YU CHUAN TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, YU CHUAN, baptized as MACARIO YU CHUAN, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Petitioner-appellee Yu Chuan filed a petition for naturalization. The Republic of the Philippines opposed the petition on the ground, among others, that Yu Chuan had been administratively fined seven times by the Bureau of Immigration for the late registration of his seven minor children, which is a violation of the Alien Registration Act. The lower court granted the petition, finding that Yu Chuan had satisfactorily explained his failure to register his children on time due to their sickness at birth and relying on the doctrine in Chay Guan Tan v. Republic.

ISSUE

Whether the petitioner’s failure to register his minor children with the Bureau of Immigration within the prescribed period, resulting in administrative fines, constitutes conduct that is not proper and irreproachable, thereby disqualifying him from naturalization.

RULING

Yes. The Supreme Court reversed the lower court’s decision. The Court held that the doctrine in Chay Guan Tan had been abandoned. Subsequent jurisprudence, specifically Co v. Republic, Chung Hong v. Republic, and Lim Guan v. Republic, established that failure to comply with the Alien Registration Act’s requirement to register minor children within the statutory period is a clear violation that renders an applicant’s conduct far from being proper and irreproachable. The petitioner’s failure to register his seven children on time, resulting in seven fines, demonstrated a lack of the proper and irreproachable conduct required for naturalization. The privilege of Filipino citizenship is reserved for the deserving, and an individual who fails to comply with legal requirements does not belong to that category. The petition for naturalization was denied.