Ramon Labo v.

COMELEC
(G.R. NO. 86564, August 1, 1989, 176 SCRA 1)
FACTS:
The petitioner, Ramon L. Labo, Jr., was proclaimed mayor-elect of Baguio City on January
1988. Because of his marriage with an Australian citizen, he was naturalized and took an oath of
allegiance as an Australian citizen. Later in his marriage with the said Australian citizen, the
Australian court declared their marriage to be void as it was found out to be bigamous.
Petitioner, however, contended that his naturalization made him only a dual citizen and that his
Filipino citizenship had not been divested of him.
ISSUE:
Whether or not Ramon Labo, Jr. maintained his Filipino citizenship?
HELD:
No. Commonwealth Act No. 63 enumerates the ways in which citizenship may be restored.
Among these are: (1) naturalization in a foreign country; (2) express renunciation of citizenship;
and (3) subscribing to an oath of allegiance to support the Constitution or laws of a foreign
country, all of which are applicable to the petitioner. Even if assumed that the petitioner’s
Australian citizenship was lost as his marriage to an Australian citizen was eventually annulled,
it did not anyway restore his Philippine citizenship.