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Political Law; Constitutional Law; Citizenship; Loss and Re-acquisition of

Philippine citizenship
Petitioner's own compliance reveals that he was originally issued a Portuguese passport in 1971, valid
for five (5) years and renewed for the same period upon presentment before the proper Portuguese
consular officer. Despite his naturalization as a Philippine citizen on 10 February 1978, on 21 July 1981,
petitioner applied for and was issued Portuguese Passport No. 35/81 serial N. 1517410 by the Consular
Section of the Portuguese Embassy in Tokyo. Said Consular Office certifies that his Portuguese
passport expired on 20 July 1986. [Yu v. Defensor-Santiago, G.R. No. L-83882, January 24, 1989]

While it is true that the law was already in effect at the time that Frivaldo became an American citizen,
nevertheless, it is not only the law itself (P.D. 725) which is tobe given retroactive effect, but even the
repatriation granted under said law to Frivaldo on June 30, 1995 is to be deemed to have retroacted to
the date of his application therefor, August 17, 1994.

Indeed, decisions declaring the acquisition or denial of citizenship cannot govern a person's future status
with finality. This is because a person may subsequently reacquire, or for that matter lose, his citizenship
under any of the modes recognized by law for the purpose. [Frivaldo v. COMELEC, G.R. No. 120295,
June 28, 1996]

Undoubtedly, petitioner Labo, not being a Filipino citizen, lacks the fundamental qualification for the
contested office. Philippine citizenship is an indispensable requirement for holding an elective office. As
mandated by law: "An elective local official must be a citizen of the Philippines." [Labo v. COMELEC,
G.R. No. 105111, July 3, 1992]

There is no doubt that he reacquired his Filipino citizenship by taking his Oath of Allegiance to the
Philippines and that he renounced his American citizenship. It is also indubitable that after renouncing
his American citizenship, Arnado used his U.S. passport at least six times. If there is any remaining
doubt, it is regarding the efficacy of Arnados renunciation of his American citizenship when he
subsequently used his U.S. passport. The renunciation of foreign citizenship must be complete and
unequivocal. The requirement that the renunciation must be made through an oath emphasizes the
solemn duty of the one making the oath of renunciation to remain true to what he has sworn to. Allowing
the subsequent use of a foreign passport because it is convenient for the person to do so is rendering
the oath a hollow act. It devalues the act of taking of an oath, reducing it to a mere ceremonial formality. [
Maquiling v. COMELEC, G.R. No. 195649, April 16, 2013]