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Loss of Citizenship

Yu v. Defensor Santiago
Portuguese passport Yus act of applying for a Portuguese passport despite his naturalization as a Philippine citizen and his act of declaring his nationality as Portuguese in commercial documents, constitute an EXPRESS renunciation of his Philippine citizenship acquired through naturalization; Philippine citizenship is not a commodity or ware to be displayed when required and suppressed when convenient

Frivaldo v. COMELEC
governor-elect of Sorsogon; American citizenship; repatriation Loss of naturalized Philippine citizenship did not and could not have the effect of automatic restoration of ones Philippine citizenship; mere filing of certificate of candidacy wherein Frivaldo claimed that he is a natural born citizen is not a sufficient act of repatriation; repatriation requires an express and unequivocal act;

Labo v. COMELEC
mayor of Baguio City; Australian citizenship; bigamous marriage Res judicata does not apply to questions of citizenship;

Modes by which Philippine citizenship may be lost:


a. naturalization in a foreign country b. express renunciation of citizenship c. subscribing to an oath of allegiance to support the Constitution or laws of a foreign country; annulment of Labos Australian citizenship as a result of finding that his marriage to an Australian national was bigamous did not automatically restore his Philippine citizenship; Philippine citizenship may be acquired by direct act of Congress; by naturalization or by repatriation.

Aznar v. COMELEC

disqualification of Osmea; American citizenship Aznar failed to present direct proof that Osmea had lost his Filipino citizenship by any of the modes provided by law; The fact the Osmea was both a Filipino and an American does not mean that he is not still a Filipino;