IN THE MATTER OF THE PETITION TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, JOHN GO CHANG, PETITIONER-APPELLEE, VS. REPUBLIC OF THE PHILIPPINES, OPPOSITOR-APPELLANT.
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John Go Chang versus Republic of the Philippines
The Case
This is John Go Chang versus the Republic of the Philippines, a naturalization case decided by the Supreme Court in April 1968. John Go Chang petitioned the Court of First Instance of Manila to be admitted as a citizen of the Philippines. The Republic opposed the petition and, when the trial court granted it, appealed to the Supreme Court. The case matters because it shows how strictly the Court reads the requirement that an applicant for naturalization must have a lucrative income, and how a single failure on that requirement defeats the petition even when the trial court has already ruled in the applicant's favor.
Procedural History
John Go Chang filed a petition for citizenship in the Court of First Instance of Manila, docketed there as Civil Case Number 50717. The trial court granted the petition. The Republic of the Philippines, as oppositor, appealed the judgment to the Supreme Court. The Supreme Court decided the appeal on a single ground and reversed the trial court.
Facts
John Go Chang filed a petition to be admitted a citizen of the Philippines in the Court of First Instance of Manila. The Republic opposed the petition. After proceedings, the trial court rendered judgment granting the petition for citizenship.
The Republic appealed. Before the Supreme Court, the decisive fact was the applicant's income. At the time the petition was filed, his annual income was 2,400 pesos, excluding bonus.
The Court found that this income was not lucrative. On that ground alone, it resolved the appeal.
Issues
- Whether or not an annual income of 2,400 pesos, bonus excluded, at the time the petition for naturalization was filed, is a lucrative income within the meaning of the law.
- Whether or not the trial court erred in granting the petition for citizenship despite the applicant's failure to show a lucrative income.
Applicable Provisions
The decision does not quote any statutory provision in full. It applies the requirement of a lucrative income, and cites prior rulings on that requirement. The Court states the governing standard in its own words:
On one ground alone, namely, that petitioner's annual income of 2,400 pesos, bonus excluded, at the time the petition was filed, is not lucrative, the appeal must be upheld.
This statement fixes the point of law on which the case turns: the applicant's income at the time of filing must be lucrative, and an income of 2,400 pesos, bonus excluded, does not meet that standard.
Ruling
On the first issue, the Court held that the applicant's annual income of 2,400 pesos, bonus excluded, at the time the petition was filed, is not lucrative. The Court did not qualify this holding; it treated the amount as falling short of the requirement as a matter of law.
On the second issue, the Court held that because the income was not lucrative, the appeal of the Republic must be upheld and the judgment granting the petition must be reversed. The Court rested its ruling on this ground alone, without needing to pass upon the other matters raised in the proceedings. The reasoning is stated in the decision's opening lines:
On one ground alone, namely, that petitioner's annual income of 2,400 pesos, bonus excluded, at the time the petition was filed, is not lucrative, the appeal must be upheld.
The Court thus measured the applicant's qualification as of the time the petition was filed, and excluded the bonus from the income considered.
Doctrine
A petition for naturalization must be supported by a lucrative income at the time the petition is filed. An annual income of 2,400 pesos, with the bonus excluded, is not lucrative. Where the applicant fails this requirement, the petition must be denied, and the judgment of the trial court granting it must be reversed on appeal. The Court may resolve the appeal on this single ground alone, without reaching the other questions in the case. For the Bar candidate, the rule to write is simple: the lucrative income requirement is jurisdictional in effect at the time of filing, the amount is assessed as of that moment, and a bonus is not counted in arriving at the figure.
Disposition
The Supreme Court reversed the judgment of the trial court, denied the petition for citizenship, and ordered the petitioner to pay the costs.
Remember This
The one line to memorize: an annual income of 2,400 pesos, bonus excluded, at the time of filing, is not lucrative, and the petition must be denied on that ground alone. Examiners use this case to test the lucrative income requirement in naturalization, especially the rule that income is measured as of the filing of the petition and that a bonus is excluded.