FRIVALDO VS COMELEC

FACTS:
Juan G. Frivaldo was proclaimed governor of the province of Sorsogon and assumed office in due time.
The League of Municipalities filed with the COMELEC a petition for the annulment of Frivaldo on the
ground that he was not a Filipino citizen, having been naturalized in the United States.
Frivaldo admitted the allegations but pleaded the special and affirmative defenses that he was naturalized
as American citizen only to protect himself against President Marcos during the Martial Law era.

ISSUE:
Whether or not Frivaldo is a Filipino citizen.

RULING:
No. Section 117 of the Omnibus Election Code provides that a qualified voter must be, among other
qualifications, a citizen of the Philippines, this being an indispensable requirement for suffrage under
Article V, Section 1, of the Constitution.

He claims that he has reacquired Philippine citizenship by virtue of valid repatriation. He claims that by
actively participating in the local elections, he automatically forfeited American citizenship under the
laws of the United States of America. The Court stated that that the alleged forfeiture was between him
and the US. If he really wanted to drop his American citizenship, he could do so in accordance with CA
No. 63 as amended by CA No. 473 and PD 725. Philippine citizenship may be reacquired by direct act of
Congress, by naturalization, or by repatriation.