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MERCADO V.

MANZANO, 307 SCRA 630

FACTS:

Petition for disqualification was filed against Edu Manzano to hold elective
office on the ground that he is both an American citizen and a Filipino citizen,
having been born in the United States of Filipino parents. COMELEC granted the
petition and disqualified Manzano for being a dual citizen pursuant to the Local
Government Code RA 7160, that those with dual citizenship are disqualified from
running any public position.

ISSUE:

Whether or not dual citizenship is a ground for disqualification to hold or run


office in the local position.

RULING:
No. Dual citizenship is different from dual allegiance. What is inimical is not
dual citizenship per se, but with naturalized citizens who maintain their allegiance
to their countries of origin even after their naturalization. Hence, the phrase “dual
citizenship” in RA 7160 must be understood as referring to “dual allegiance”.
Consequently, persons with mere dual citizenship do not fall under this
disqualification.

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