G.R. No. L-4688; February 16, 1953
In the matter of the petition of WU SIOCK BOON (alias) LAM HOY to be admitted a citizen of the Philippines. WU SIOCK BOON (alias) LAM HOY, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

The petitioner-appellant, Wu Siock Boon (alias Lam Hoy), a Chinese citizen born in Canton, China in 1919, immigrated to the Philippines in 1928 and has continuously resided here since, living in Jolo, Sulu. He is a merchant with a business worth over P14,000, a certified Chinese druggist, and a 7th-grade graduate of the Central School of Jolo. He is married to a native Moro girl, Lim Surian of Cagayan de Sulu, and they have two children. He claims to be an orphan with no living relatives in China and desires to make the Philippines his home. The trial court denied his application for naturalization on four grounds: failure to prove (1) continuous residence for the required period, (2) ability to speak and write English and a principal Filipino language, (3) understanding of the principles underlying the Philippine Constitution, and (4) social mingling with Filipinos. The appellant appealed, contending these findings were contrary to the evidence.

ISSUE

The primary issue for determination is whether the applicant speaks and writes any of the principal Philippine languages and understands the principles underlying the Philippine Constitution, as the Solicitor General conceded the other points regarding continuous residence, ability in English, and social mingling.

RULING

The Supreme Court reversed the trial court’s decision and granted the application for naturalization.
1. On the requirement to speak and write a principal Philippine language: The Court held that the Tausug (or Joloano) and Chavacano dialects qualify as “principal” dialects because they are spoken by a substantial portion of the population in the Philippines (Sulu, Cavite, Zamboanga, and other parts of Mindanao). Knowledge of these, in addition to English, is sufficient for social integration. While the applicant’s ability to write them was initially doubtful, a practical test during trial (Exhibit 1) demonstrated his ability to write English and its translation into Chavacano. The Court also took judicial notice that the same alphabet is used for writing English, Spanish, and native dialects, so one proficient in writing English can be expected to write a known dialect.
2. On the requirement to understand the principles underlying the Philippine Constitution: The Court found the applicant’s answer on cross-examination—that he understood it to mean “that the Philippine government is run under three departments: executive, legislative and judiciary”—to be correct and indicative of some knowledge. The tripartite system with separation of powers is a basic feature of the government. The Court cited precedent (Vicente Pang Kok Hua vs. Republica de Filipinas) stating that the naturalization law does not require an applicant to answer all possible questions about the Constitution; to demand more would be to amend the law judicially.
The applicant was therefore admitted to Philippine citizenship, subject to the usual conditions.