Choy v. Republic

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Facts:

Petitioner-appellee Fong Choy, also known as Carlos Yee, filed a petition for naturalization. During the hearing, he admitted that he had previously paid a P25 fine for violating the Price Tag Law (R.A. No. 71), explaining that all items in his store were tagged, but the price tag of one article had fallen off and was missing when an inspector arrived. He stated he paid the fine "to avoid further discussion."

Despite this admission and opposition from the Republic of the Philippines, the trial court (Judge Francisco Geronimo) granted the petition on March 24, 1965, ruling that petitioner possessed all the qualifications and none of the disqualifications under the law.

The Republic appealed, arguing that such a violation reflected conduct that was not proper and irreproachable, a necessary qualification under Section 2 of the Revised Naturalization Law (C.A. No. 473).

Issue:

Whether the grant of naturalization can stand despite the petitioner’s admitted violation of the Price Tag Law, and whether such conduct bars him from being considered as having lived in a “proper and irreproachable manner.”

Ruling:

The Supreme Court REVERSED the lower court’s decision and DENIED the petition for naturalization.

Reasoning / Legal Doctrine:

  • The Court cited its earlier ruling in Tio Tek Chai v. Republic (1964), where a similar violation of the Price Tag Law was found to negate the requirement of proper and irreproachable conduct. That ruling was held to be binding precedent, which the trial court erroneously disregarded.

  • In Tio Tek Chai, the Court held that even if the violation did not involve moral turpitude, it nonetheless demonstrated unacceptable conduct that failed to meet the strict standards required for naturalization.

  • The Court emphasized that:

    “It is not enough that an applicant be not disqualified... it is also required that he be possessed of the qualifications enumerated in Section 2. And among those qualifications is that he must have conducted himself in a proper and irreproachable manner...”

  • The Supreme Court viewed petitioner’s explanation—that the tag “just fell off”—as implausible and as an attempt to justify the inexcusable. The Court criticized the credulity of the lower court in accepting such explanation.

  • The ruling emphasized the strict and rigorous standards for naturalization, stating:

    “The boon of nationality... is to be accorded only to those who, by their exemplary behavior and conduct, have earned the title-deed to membership in our political community.”

Conclusion:

The Supreme Court reversed the decision of the trial court. Petitioner Fong Choy's violation of the Price Tag Law disqualified him from naturalization as it showed that he did not conduct himself in a proper and irreproachable manner.

Doctrine / Principles for Law Students:

  1. Naturalization is not a right but a privilege, granted only to those who meet both positive qualifications and are free from disqualifications under C.A. No. 473.

  2. The requirement to have conducted oneself in a “proper and irreproachable manner” (Sec. 2 of C.A. 473) is a substantive qualification, separate and distinct from not having been convicted of a crime involving moral turpitude.

  3. Lower courts are bound by Supreme Court rulings. In this case, the trial court erred by disregarding the binding precedent set in Tio Tek Chai v. Republic.

  4. Violations of laws designed to protect the public interest (such as the Price Tag Law) may render an applicant unfit for citizenship, even if the offense is minor or penalized by a small fine.

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