Grace Poe v.

COMELEC
GR 221697, GR 221698-700 March 8, 2016
FACTS:
Grace was a foundling, born in 1968, and was adopted by spouses Poe in 1972. She became
a naturalized American citizen in 2001 but reacquired her Philippine citizenship in 2006
pursuant to RA 9225.
Grace filed her COC for President in 2015 for the 2016 elections, but this triggered the filing
of several COMELEC cases against her on the ground of, among others, her citizenship.
ISSUE:
W/N foundlings in the Philippines should be considered natural-born Filipinos.
RULING:
Yes. Though the status of foundlings cannot be found in our past and present Constitutions,
the 1934 Constitutional Convention shows that it was really the intention of the framers not
to include them for the reason that under the principles of international law, it has already
been recognized that foundlings follow the nationality of the place where they are found. As
the framers put it, referring to international law, the principle that children or people born in
our country of unknown parents are citizens of this nation is recognized, and it is not
necessary to include a provision on the subject exhaustively.
Hence, following the intention of the framers, adopting the generally accepted principles of
international law, foundlings born in the Philippines are considered natural-born Filipinos.