G.R. No. L-5047 May 8, 1952
VICENTE PANG KOK HUA, petitioner and appellant, vs. THE REPUBLIC OF THE PHILIPPINES, oppositor and appellee.

FACTS

The petitioner, Vicente Pang Kok Hua, was born on October 27, 1927, in Angadanan, Isabela, Philippines, to Chinese parents. He completed his elementary education in government-recognized schools in Isabela and Manila, including the Anglo-Chinese School. He finished high school at Bohol Junior Colleges in Manila and graduated from the Far Eastern University’s School of Commerce. He has never been to China and has associated with Filipinos since birth. At the time of the hearing, he was an assistant manager with a salary of P2,400 at Pang Seng Tiac & Sons Co., a tobacco business where he held a P10,000 interest. He was not otherwise disqualified from acquiring Philippine citizenship. The Court of First Instance of Manila denied his petition for naturalization in an order dated November 21, 1950, due to his inability to state the principles underlying the Philippine Constitution and the customs, traditions, and ideals of the Filipinos, which he pledged to support and embrace. The petitioner appealed this decision.

ISSUE

Whether the petitioner’s inability to verbally state the principles of the Philippine Constitution and Filipino customs, traditions, and ideals during the hearing is a valid ground for denying his application for naturalization under the applicable law.

RULING

The Supreme Court reversed the appealed order and granted the petitioner’s naturalization. The Court held that the naturalization law does not require the applicant to answer, if asked, what the basic principles of the Philippine Constitution are or what the customs, traditions, and ideals of the Filipinos are that he promises to adopt. The law only requires that the applicant has studied in government schools or government-recognized schools, completing elementary and high school courses. The diploma from Bohol Junior Colleges (Exhibit “H”) was sufficient proof of compliance with this requirement. The Court presumed that during this educational process, the student assimilates the customs, traditions, and ideals of Filipinos and becomes informed of the principles underlying the Philippine Constitution and government. Failure to answer questions on these matters during the hearing does not necessarily mean the applicant is unaware of them; it could be due to lack of facility in expression, nervousness, or a momentary lapse of memory. To require such verbal articulation imposes a condition beyond what the law prescribes and amounts to a judicial amendment of the law.