Jacot vs. Dal 

GR. 179848, November 27, 2008   To hold the oath to be a mere proforma
requirement is to say that it is merely for
ceremonial purposes resulting in a mere or
Jacot applied for re-acquisition of his Filipino
qualified allegiance when the constitution or
Citizenship under R.A. 9225; upon approval Jacot
legislature demands otherwise.  
took his oath of allegiance to the Republic of the
Unless she executes a sworn renunciation of her
Philippines.  
Australian Citizenship , she is ineligible to run and
He then filed a certificate of candidacy. A
hold for any elective office. 
disqualification was filed against him on the
 
ground that he failed to renounce his US
ISSUE: WON the Australian Citizen Act under
citizenship as required by Section 5(2) of R.A.
which she is deemed to have lost her citizenship is
9225.
entitled to judicial notice? 
ISSUE: WON the oath of allegiance and the oath
HELD: No. Foreign laws must be alleged and
contained in his certificate of candidacy operated
proven. Petitioner failed to prove the Australian
as an effective renunciation of his foreign
Citizenship Act of 1948. If the aforesaid act will be
citizenship. 
read into the application and operation of RA 9225
we would be applying not what our legislative
HELD: Nothing in the oath of allegiance and the
department has deemed wise to require.  
oath contained in the certificate of candidacy
provides for the renunciation of foreign
 
citizenship. Jacot is disqualified from running as a Maquiling v. COMELEC 
candidate.  G.R. 195649, April 16, 2013
Section 5(2) of R.A. 9225 compels natural born
Filipinos, who have been naturalized citizens of Before filing for certificate of candidacy, Arnado
foreign country, but who reacquired or retained applied for repatriation under RA 9225 where he
their Philippine citizenship to:  took an oath of allegiance to the Republic of the
1. Take the oath of allegiance under Section 3 of Philippines and executed an affidavit of
R.A. 9225 and;  renunciation of U.S. Citizenship
2. For those seeking elective public offices in the The other mayoralty candidate seek to disqualify
Philippines, to additionally  execute a personal and Arnado on the ground that Arnado continued to
sworn renunciation of any or all foreign citizenship use his U.S. passport in his travels abroad even
before an authorized public officer or simultaneous after executing an affidavit of renunciation.  
to the filing of their certificate of candidacy, to  
qualify as candidates in Philippine Election.   ISSUE: WON the use of foreign passport amounts
to undoing an earlier renunciation?

RULING: The act of using foreign passport does not

Sobejana-Condon v COMELEC  by itself divest Arnado of Filipino citizenship but
GR. 198742, August 10, 2012 the representation of himself as American citizen.
   The Filipino citizenship requirement for an elective
Petitioner took the Oath of Allegiance on December public office is a continuing one. Any act which
05, 2000. Nine months later she filed an unsworn violated the oath opens the citizenship issue to
declaration of Renunciation of Australian attack. 
Citizenship before the Dept. of Immigration and
Indigenous Affairs, said office subsequently issued Arnado vs COMELEC 
a certification that she has ceased to be an
GR. 210164, August 18, 2015 
Australian citizen.  
The petitioner won as Vice Mayor but a quo
The court decided Maquiling on April 16, 2013,
warranto proceedings was filed against her on the
after the lapse of the period for filing of Certificate
ground that she failed to renounce her foreign
of Candidacy. On May 09, 2013 Arnado submitted
citizenship as required by Section 5(2) of RA 9225
an affidavit affirming his affidavit of renunciation
which provides that renunciation must be sworn
dated April 3, 2009.  
before an officer authorized to administer an
On 2013 elections Arnado won. The other
oath.  
candidate filed a petition to nullify Arnado’s
proclamation .
ISSUE: WON the sworn renunciation of foreign
citizenship is a mere pro-forma requirement? 
ISSUE: WON Arnado complied with the
requirement of personal and sworn renunciation
Held: The court ruled in the case of Lopez vs
of any and all foreign citizenship prior to or at the
COMELEC that renunciation must be contained in
time of the filing of his certificate of candidacy. 
an affidavit duly executed before an officer of the
law who is authorized to administer an oath
HELD: Arnado’s use of passport in 2009
stating in clear and unequivocal terms that affiant
invalidated his oath of renunciation resulting in his
is renouncing her foreign citizenship.  
disqualification in the 2010 election. Since then
 and up to the time he filed his CoC for the 2013 ISSUE: Whether Muneses is entitled to resume his
elections, Arnado has not cured the defect in his practice of law in the Philippines after he lost and
qualifications. The ruling in Maquiling, therefore is later re-acquired his Philippine citizenship?
binding on this case.
HELD: Yes, A Filipino lawyer who becomes a
  citizen of another country and later re-acquires his
 REACQUISITION VS RETENTION Philippine citizenship under R.A. 9225, remains to
be a member of the bar. However the right to
resume practice of law is not automatic. He must
Reacquisition Retention apply with the proper authority for a license or
RA 9225 permit to engage in such practice.
Sept. 17,
2003
Naturalized before RA Naturalized after RA
9225 9225
Not considered as Considered as Filipinos
Filipinos from the time from naturalization up-
of their naturalization to the time they took an
up-to taking of oath of oath of allegiance.
allegiance.
DAVID v. AGBAY
G.R. 199113, March 18, 2015

On 1974 Petitioner became a Canadian Citizen by

naturalization.
On April 2007, Petitioner applied for Miscellaneous
Lease Application with the DENR, petitioner
indicated in is application that he was a Filipino.
On October 2007, petitioner re-acquired his
Philippine citizenship. A case for falsification of
public documents was filed against Petitioner.
Petitioner asserts that re-acquisition and retention
in RA 9225 should not be distinguished in view of
the constitutional presumption of innocence. The
petitioner being a non-lawyer at the time of the
commission of the offense.

ISSUE: WON Petitioner is liable for falsification.

HELD: Petitioner made the untruthful statement in

the MLA, a public document. Stating that he is
Filipino citizen at the time of the filing of said
application when in fact he was still then a
Canadian Citizen. While he re-acquired Philippine
citizenship under RA 9225 six months later. The
falsification was already consummated. The said
law having no retroactive effects insofar as his dual
status is concerned.

Practice of Profession
 The practice of professions being a privilege
is therefore restricted to Philippine Citizens.
 Foreigner is not allowed to practice his
professions without obtaining a permit or
license.

IN RE: PETITION TO RE-ACQUIRE THE

PRIVELEGE TO PRACTICE LAW IN THE
PHILIPPINES
B.M. No. 2112, July 24, 2012