Appeal from a decision of the Court of  First Instance of Manila, Hon. Gregorio Narvasa, presiding, denying the application for naturalization of Lim Siong, a native and citizen  of  China.

The  petition for naturalization  alleges  that the  petitioner Lim Siong is a subject  of the  Republic of China, born in Amoy, China on November  30, 1907; that he came to the Philippines on or about October 22, 1926, about some 29 years before he filed his  petition; that he married Tan Chit, also a citizen of China, and with her have 8 children, namely, Lim Sok Chong, Lim Sok Beng, Lily Lim, James Lim, Luis  Lim, Nelson Lim, Nancy Lim and Eduard Lim; that he believes in the principles underlying the Constitution, has mingled with Filipinos, and  has all the qualifications required in  Section  2  of Commonwealth Act No. 473, and none  of the disqualifications contained in Section 1 thereof.  The petition was  set  for hearing  after due publication, and after trial  the court  rendered judgment finding that the first two children of the petitioner,  namely, Lim Sok Chong and Lim Sok Beng,  have finished their elementary education in China and came to the Philippines only in 1948; that said two children were born in China on February 5,  1931 (Lim Sok Chong)  and on  May  4, 1933 (Lim Sok Beng);  that  their mother came  to the Philippines in  1938,  but said  two  sons were left behind in China and  they came to this  country  only in  1948, after they had completed the elementary grades in China; that the said children  enrolled in the Philippine  private schools and colleges, but that they have not been enrolled during  the entire period of  the residence required of the applicant prior to the filing of the petition,  i.e., ten years. The court, therefore, held that  petition for naturalization must be denied, because the petitioner failed to comply with the requirement of Section  2,  par.  6,  of Commonwealth Act  473.

The petitioner in this appeal does not question the above findings of the court  below,  but claims that inasmuch as the two children above-mentioned were enrolled in schools required by law for at least nine years prior to the hearing of the petition and are still studying up to now, the alleged failure of the petitioner to comply with the requirements of the law is neither clear nor apparent; that the provision of law upon which the denial of the petition is based does not  require a literal compliance,  such as to require that petitioner's children must  be enrolled actually during the entire period of 10 years required therein.  Authority for this contention  is the case of Pritchard  vs. Republic, 81 Phil., 244.

We have examined said case, and we find that the question therein is whether or  not the petitioner had complied with Section 5 of the Naturalization Law, the requirement of which is similar to that of Section 2, par. 6 of the same law.  The Court in  said case held as follows:

"* * *.  The legal provision requiring  that the applicant  'has given primary  and secondary education to all his  children in the private or public schools  recognized by the government' should be construed in the  sense  that, if  the  applicant  has children,  and they are of school age, they should be  given primary or secondary education in the  schools  mentioned by the law.  The words  'has given' should be interpreted to  mean that the children,  if of school age, should be given the opportunity of getting primary or secondary education,  by their  opportune enrollment and attendance in the schools  mentioned by the  law, but not  that  both must have completed in said schools both primary and secondary education.* * *."

In  the case at bar,  the judge did  not reject the application because  of applicant's failure to  have  his  two children complete studies  in Philippine elementary and high  schools.   It is his failure to enroll them during the entire period of the residence "of 10 years, as  required in Section 2,  pars. 2 and 6,  that  was the reason for the denial.  The  children  of the petitioner. above-mentioned were enrolled when at school  age in schools  in China, and continued to be enrolled therein up to 1948.  The requirement of the law is that applicant must enroll his children in  Philippine schools when they  are of school age  and during the period of  10 years.   Its evident  purpose  is to  have the children given the training that the country desires of its citizens, so they will become useful members of  the country upon their parents' admission.   In the  case at  bar, the foundations of the education of the first  two children were obtained  in  China, not in the Philippines, they having come to this country when they were already 17 and 15  years of age.  The petitioner tried to comply with the law upon his children's arrival in  1948, but  then only 3 years for the older and 5  years for the younger remained of their school age, or  before they Would reach the age of majority, at which time they are supposed more or  less to earn their own livelihood and engage in a calling. It  is not true, therefore, that there has been a,substantial compliance  with the requirement  of the law, because, from the ages of 7 to 17 and  15, they actually studied in China. Fully  ten years of their school age were spent in China, not in the  Philippines.  For this  reason,  it can not be said that the law has  been  substantially complied with, even if we  were to be liberal in its application.

The  Solicitor General has,  aside  from  the above objection, interposed another, which is that  of  petitioner's honesty.  According to his testimony,  the  petitioner  had an average income in the years 1955 and 1956 at P6,000 a year, but in  his  income tax he reported only a gross income of P1,982.89 for 1955 and P1,702,11 for 1956.  It is  of  public  knowledge that  one of the most important problems of this Government  is the difficulty of collecting taxes.  The failure of the applicant  to report his income affects his  honesty, to  the detriment of the country, he wants to be a citizen of. Section 2, par. 3 of the Naturalization Law requires that  an  applicant must  be of good moral character.  Failure of the applicant to enter his  true income in his tax returns is conclusive evidence of his  lack of  honesty,  which means  lack  of good moral character. This fact also renders applicant ineligible for admission as a citizen of the Philippines.

For the foregoing considerations, the decision  appealed from is hereby affirmed, not only on the ground stated in the judgment, but also on the additional ground that the applicant does not possess good moral character.  With costs.  So  ordered.

Paras, C.  J., Bengzon, Padilla,  Reyes, A., Bautista Angelo, Concepcion, and Endencia, JJ., concur.