MERCADO vs.

MANZANO
G.R. NO. 135083
May 26, 1999

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.