GR L 5029; (May, 1953) (Digest)
G.R. No. L-5029; May 22, 1953
In the matter of the petition of CHUA TIONG CHIA to be admitted as citizen of the Philippines. CHUA TIONG CHIA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Chua Tiong Chia filed a petition for naturalization as a citizen of the Philippines. The Republic of the Philippines opposed the petition on three main grounds. First, the petitioner filed his income tax returns for the years 1945, 1946, and 1947 only in 1951, after being required to exhibit them during the hearing. Second, the petitioner made mistakes during the trial concerning the dates of his marriage and the birth of his daughter, which he attributed to confusion in converting dates from the Chinese to the Gregorian calendar. Third, the Republic argued that the petitioner’s supporting witnesses, Vicente de la Cruz and Toribio Angeles, who had known him only since 1935 and 1937 respectively, could not truthfully attest that they personally knew him to be a resident of the Philippines for the continuous period of 30 years, which the Republic contended was required because the petitioner was not born in the Philippines and did not file a declaration of intention one year prior to his petition.
ISSUE
Whether the grounds for opposition raised by the Republic of the Philippines are meritorious to deny the petition for naturalization of Chua Tiong Chia.
RULING
The Supreme Court affirmed the decision of the Manila court of first instance approving the naturalization. The Court found none of the grounds of opposition meritorious. Regarding the belated income tax payments, the Court noted the objection was not pressed below and that the Bureau of Internal Revenue had accepted a compromise, making it inequitable to further disadvantage the petitioner. Concerning the mistaken dates, the Court accepted the petitioner’s explanation of calendar confusion and found the inaccuracies immaterial as his familial relationships were not in doubt. On the crucial issue of the witnesses’ knowledge of the petitioner’s residence, the Court held that the “period of time required by this Act” referred to in Section 7 of the Revised Naturalization Law (Commonwealth Act 473) pertains to the residence periods specified in Sections 2 and 3 (ten or five years), not the 30-year period mentioned in Section 6, which only pertains to exemption from filing a declaration of intention. Since the witnesses had known the petitioner for more than ten years, the statutory requirement was satisfied. The Court also noted the trial court’s detailed findings on the petitioner’s qualifications, demonstrating he deserved admission to Philippine citizenship.