In Mercado vs. Manzano and COMELEC, G.R. No.

135083, May 26, 1999, the

Supreme Court has consistently followed the rule that in order that citizenship
may be lost by renunciation, such renunciation must be express. In the case at
bar, the renunciation of private respondent Eduardo Manzano’s American
citizenship was deemed in effect with his acts of filing a certificate of candidacy
when he ran for elective office as vice mayor of the City of Makati in the 1998
elections and taking the oath of allegiance to the Republic.