Bar Matter No.

914
 Alien Father, Filipino Mother
 Only elected citizenship 14 years after reaching the age of majority – 35 yrs
old
(21 yrs old age of majority)
 Took BAR exams but was not admitted
 Did not elect citizenship within reasonable time – 3 yrs after reaching age of
majority
 3 years may be extended if person lived as a Filipino his whole life BUT
according to jurisprudence, electing at age of 28 is not within reasonable
time

Bengson III vs HRET

 Private respondent, Teodoro Cruz, had his eligibility to be in the House of
Representative questioned by virtue of his enlistment to the US Marine Corps
a few years ago
 Cruz was repatriated to the Philippines prior to joining the House of
Representative
 Cruz may be considered a natural born. REPATRIATION unlike naturalization
reverts a person’s citizenship to his original one.

Kilosbayan vs Eduardo
 Private Respondent, Gregory Ong substituted in the position of a retired
associate justice.
 Petitioners allege that Ong is Chinese (according to Birth Certificate)
 Respondent contends that Ong is a natural born citizen, as declared by the
Bureau of Immigration (Father was naturalized when Gregory was a minor;
mother is Chinese)
 Gregory Ong may not be considered as natural born because he did not file a
proper petition to correct his nationality, as stated in his birth certificate – A
mere administrative proceeding is not sufficient

AZNAR vs COMELEC
 Private respondent, Lito Osmeñ a filed a certificate of candidacy for Governor
in Cebu
 Petitioner allege that Osmena is an American who even has an Alien
Certificate of Registration
 Issue: Whether or not Osmena is a citizen of the Phil
 Held: Yes, because petitioners failed to prove that Osmena lost his citizenship
by naturalization abroad, express renunciation or oath of allegiance abroad
 Osmena has a Filipino father and even a grandfather who was a former
president, Therefore, the presumption is that he is Filipino unless the same is
sufficiently disproved
MERCADO VS MANZANO
 Manzano won the vice-mayor position in Makati; However, Mercado, a
competitor, alleged that he is a US citizen according to Bureau of Immigration
records
 Manzano was subsequently determined to have dual citizenship, born in Us
with Filipino parents
 Mnazano has taken an oath of allegiance to the Philippines (registered
himself as a voter upon reaching the age of majority) and has lived his life as
a Filipino youth
 Issue: Whether or not Manzano is a citizen of Phil
 Held: Yes, he has effectively renounced his US citizenship and has even lived
as a Filipino

CO VS HRET
 Private Respondent, Jose Ong, won the elections in Samar as Congressman
 Petitoner, the candidate who lost, questioned his citizenship
 Ong lived, studied and worked in the Philippines his whole life, but his Father
was originally Chinese and was only naturalized when Jose was 9 yrs old.
Jose’s mother is a Filipino
 Petitioner contend that given Ong’s situation, he should have elected
Philippine Citizenship
 Issue: Whether or not Jose Ong may be considered as natural born, by virtue
of his non-election of Philippine Citizenship
 Held: Jose Ong did not need to elect Philippine Citizenship, for he has lived
his whole life as a Filipino, without any quality that can render him as an
alien. A formal election of citizenship is only required for those that need to
do so in order to affirm their allegiance to the Philippines. Moreover, the fact
that his father become a naturalized Filipino should clear any doubts as to his
citizenship.

YU VS DEFENSOR-SANTIAGO
 Willie Yu was naturalized as a Filipino citizen, but he still used his
Portuguese passport (even renewed it), and stated he was Portuguese in his
commercial dealings in HK
 Pending to the decision of the case, Yu was detained and possibly subject to
deportation
 Issue: Whether or not Yu renounced his naturalized Filipino citizenship
through his acts
 Held: Yes, it is clear that Yu has done acts equivalent to renouncing his
Filipino citizenship. Also, he did not deny the above facts.
SO VS REPUBLIC
 Edison So, Chinese, has lived in the Phil since birth, currently studying med in
UST, applying for naturalization
 Submitted all documents needed and also presented two witnesses to prove
his good moral character, lack of impediments etc.
 Witnesses: a lawyer family friend and a classmate in UST
 Respondent contended that his witnesses only said general statements and
did not know him on a personal level
 Held: So may not be a naturalized citizen because witnesses did not know
him personally and he did not prove his witnesses’ good moral character

MAQUILING VS COMELEC
 Maquiling was the former mayor in a town in Lanao del Norte
 He ran for vice mayor following his term, but his citizenship was questioned.
 He was naturalized in US, but repatriated to the Phil YET he used his US
passport 4 times after repatriation.
 Maquiling contended that he did so because his Phil passport was not yet
issued at that time
 It was ruled by a division of the comelec that Maquiling had a valid cause for
using his US passport and that what he did was not a ground for renunciation
of his citizenship.
 The SC ruled that even if the act does not result in the loss of his Fil
citizenship, IT DOES REPUDIATE HIS SUPPOSED RENUNCIATION OF HIS US
CITIZENSHIP which is a requirement for running for the elections
 His former position as mayor does not form a valid ground for estoppel

SOBEJANA-CANDON VS COMELEC
 Disqualified as vice-mayor of Caba, La Union, The petitioner was naturalized
as Australian through marriage
 Petitioner applied for reacquisition of Phil citizenship but only supported her
application with an UNSWORN renunciation of Australian citizenship
 She lost in the 2007 mayoral election but won as vice-mayor in 2010
 Her 2010 win was questioned by virtue of her dubious reacquisition
 Petitioner contended that her unsworn renunciation of Aus citizenship
merely involved a formal process
 SC ruled that it is an ESSENTIAL part of the procedure provided in RA 9225
 Note: Prior to RA 9225, mere filing of cert of candidacy may renounce
citizenship in another country.