CONSTITUTIONAL 1 CASE DIGESTS | CITIZENSHIP

I. Tecson v COMELEC
G.R. No. 161434, March 3, 2004

FACTS:
Section 2, Article VII, of the 1987 Constitution expresses:
"No person may be elected President unless he is a natural-born citizen of the Philippines, a
registered voter, able to read and write, at least forty years of age on the day of the election, and
a resident of the Philippines for at least ten years immediately preceding such election."
The term "natural-born citizens," is defined to include "those who are citizens of the Philippines
from birth without having to perform any act to acquire or perfect their Philippine citizenship."

Respondent Ronald Allan Kelly Poe, also known as Fernando Poe, Jr. (hereinafter
"FPJ"), filed his certificate of candidacy for the position of President of the Republic of the
Philippines under the Koalisyon ng Nagkakaisang Pilipino (KNP) Party, in the forthcoming
national elections. In his certificate of candidacy, FPJ, representing himself to be a natural-born
citizen of the Philippines, stated his name to be "Fernando Jr.," or "Ronald Allan" Poe, his date
of birth to be 20 August 1939 and his place of birth to be Manila.
Victorino X. Fornier initiated a petition before the COMELEC to disqualify FPJ and to
deny due course or to cancel his certificate of candidacy upon the thesis that FPJ made a material
misrepresentation in his certificate of candidacy by claiming to be a natural-born Filipino citizen
when in truth, according to Fornier, his parents were foreigners; his mother, Bessie Kelley Poe,
was an American, and his father, Allan Poe, was a Spanish national, being the son of Lorenzo
Pou, a Spanish subject.
Granting, Fornier asseverated, that Allan F. Poe was a Filipino citizen, he could not have
transmitted his Filipino citizenship to FPJ, the latter being an illegitimate child of an alien
mother. Fornier based the allegation of the illegitimate birth of FPJ on two assertions: (1) Allan
F. Poe contracted a prior marriage to a certain Paulita Gomez before his marriage to Bessie
Kelley and, (2) even if no such prior marriage had existed, Allan F. Poe, married Bessie Kelly
only a year after the birth of FPJ.
The COMELEC dismissed the petition for lack of merit. 3 days later Fornier filed his
motion for reconsideration. The motion was denied by the COMELEC en banc. Fornier assailed
the decision of the COMELEC before the Supreme Court conformably with Rule 64, in relation
to Rule 65, of the Revised Rules of Civil Procedure
The petition likewise prayed for a temporary restraining order, a writ of preliminary
injunction or any other resolution that would stay the finality and/or execution of the COMELEC
resolutions.

ISSUE:

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1. Whether or not FPJ is a natural born Filipino which is one of the requirement in running for
presidency.
2. Whether or not Allan F. Poe can transmit his Filipino citizenship to FPJ.

RULINGS:
1. Yes. The date, month and year of birth of FPJ appeared to be 20 August 1939 during the
regime of the 1935 Constitution which provides that among the citizens of the Philippines are
"those whose fathers are citizens of the Philippines."

Tracing respondent’s paternal lineage, his grandfather Lorenzo Pou, as evidenced by the latter’s
death certificate was identified as a Filipino Citizen. Under the Philippine Bill of 1902, also
commonly referred to as the Philippine Organic Act of 190 which states that
" all inhabitants of the Philippine Islands continuing to reside therein, who were Spanish subjects
on the 11th day of April, 1891, and then resided in said Islands, and their children born
subsequent thereto, shall be deemed and held to be citizens of the Philippine Islands and as such
entitled to the protection of the United States, except such as shall have elected to preserve their
allegiance to the Crown of Spain in accordance with the provisions of the treaty of peace
between the United States and Spain, signed at Paris, December tenth eighteen hundred and
ninety eight."
The death certificate of Lorenzo Pou would indicate that he died on 11 September 1954, at the
age of 84 years, in San Carlos, Pangasinan. It could thus be assumed that Lorenzo Pou was born
sometime in the year 1870 when the Philippines was still a colony of Spain.
Hence FPJ is a Natural Born Citizen.

2. Yes, FPJ having been acknowledged as Allan’s son to Bessie, though an American
citizen, was a Filipino citizen by virtue of paternal filiation as evidenced by the respondent’s
birth certificate. The 1935 Constitution on citizenship did not make a distinction on the
legitimacy or illegitimacy of the child, thus, the allegation of bigamous marriage and the
allegation that respondent was born only before the assailed marriage had no bearing on
respondent’s citizenship in view of the established paternal filiation evidenced by the public
documents presented.

WHEREFORE, the Court RESOLVES to DISMISS

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II. Mo Ya Lim Yao vs Comission on Immigration

G.R. No. L-21289 October 4, 1971

Facts:

Petitioners seek the issuance of a writ of injunction against the Commissioner of

Immigration, "restraining the latter and/or his authorized representative from ordering plaintiff
Lau Yuen Yeung to leave the Philippines and causing her arrest and deportation and the
confiscation of her bond, upon her failure to do so.

Lau Yuen Yeung applied for a passport visa to enter the Philippines as a non-immigrant.
In the interrogation made in connection with her application for a temporary visitor's visa to
enter the Philippines, she stated that she was a Chinese residing at Kowloon, Hongkong, and that
she desired to take a pleasure trip to the Philippines to visit her great (grand) uncle Lau Ching
Ping for a period of one month.

She was permitted to come into the Philippines and was permitted to stay for a period of
one month. On the date of her arrival, Asher Y, Cheng filed a bond to undertake, among others
that said Lau Yuen Yeung would actually depart from the Philippines on or before the expiration
of her authorized period of stay in this country or within the period as in his discretion the
Commissioner of Immigration or his authorized representative might properly allow. After
repeated extensions, petitioner Lau Yuen Yeung was allowed to stay in the Philippines up to
February 13, 1962.

She contracted marriage with Moy Ya Lim Yao alias Edilberto Aguinaldo Lim an alleged
Filipino citizen. Because of the contemplated action of respondent to confiscate her bond and
order her arrest and immediate deportation, after the expiration of her authorized stay, she
brought this action for injunction with preliminary injunction. At the hearing which took place
one and a half years after her arrival, it was admitted that petitioner Lau Yuen Yeung could not
write either English or Tagalog. Except for a few words, she could not speak either English or
Tagalog. She could not name any Filipino neighbor, with a Filipino name except one, Rosa. She
did not know the names of her brothers-in-law, or sisters-in-law.

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Issue:

1. Whether or not Lau Yuen Yeung ipso facto became a Filipino citizen upon her
marriage to a Filipino citizen.

Ruling:

Yes. Under Section 15 of Commonwealth Act 473, an alien woman marrying a Filipino,
native born or naturalized, becomes ipso facto a Filipina provided she is not disqualified to be a
citizen of the Philippines under Section 4 of the same law. Likewise, an alien woman married to
an alien who is subsequently naturalized here follows the Philippine citizenship of her husband
the moment he takes his oath as Filipino citizen, provided that she does not suffer from any of
the disqualifications under said Section 4. Whether the alien woman requires to undergo the
naturalization proceedings, Section 15 is a parallel provision to Section 16. Thus, if the widow of
an applicant for naturalization as Filipino, who dies during the proceedings, is not required to go
through a naturalization proceedings, in order to be considered as a Filipino citizen hereof, it
should follow that the wife of a living Filipino cannot be denied the same privilege.

This is plain common sense and there is absolutely no evidence that the Legislature
intended to treat them differently. As the laws of our country, both substantive and procedural,
stand today, there is no such procedure (a substitute for naturalization proceeding to enable the
alien wife of a Philippine citizen to have the matter of her own citizenship settled and established
so that she may not have to be called upon to prove it everytime she has to perform an act or
enter into a transaction or business or exercise a right reserved only to Filipinos), but such is no
proof that the citizenship is not vested as of the date of marriage or the husband's acquisition of
citizenship, as the case may be, for the truth is that the situation obtains even as to native-born
Filipinos.
The judgment of the Court a quo dismissing appellants' petition for injunction is hereby
reversed and the Commissioner of Immigration and/or his authorized representative is
permanently enjoined from causing the arrest and deportation and the confiscation of the bond of
appellant Lau Yuen Yeung, who is hereby declared to have become a Filipino citizen from and
by virtue of her marriage to her co-appellant Moy Ya Lim Yao alias Edilberto Aguinaldo Lim, a
Filipino citizen on January 25, 1962. No costs.

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III. Valles vs COMELEC

G.R. No. 137000. August 9, 2000

Facts:

Rosalind Ybasco Lopez was born on May 16, 1934 in Napier Terrace, Broome,
Western Australia, to the spouses, Telesforo Ybasco, a Filipino citizen and native of Daet,
Camarines Norte, and Theresa Marquez, an Australian. In 1949, at the age of fifteen, she left
Australia and came to settle in the Philippines.

She was married to Leopoldo Lopez, a Filipino citizen, at the Malate Catholic Church in
Manila. Since then, she has continuously participated in the electoral process not only as a voter
but as a candidate, as well. She served as Provincial Board Member of the Sangguniang
Panlalawigan of Davao Oriental. In 1992, she ran for and was elected governor of Davao
Oriental.

Her election was contested by her opponent, Gil Taojo, Jr., in a petition for quo warranto,
docketed as EPC No. 92-54, alleging as ground therefor her alleged Australian
citizenship. However, finding no sufficient proof that respondent had renounced her Philippine
citizenship, the Commission on Elections en ban cdismissed the petition.

In the 1995 local elections, respondent Rosalind Ybasco Lopez ran for re-election as
governor of Davao Oriental. Her opponent, Francisco Rabat, filed a petition for disqualification,
docketed as SPA No. 95-066 before the COMELEC, First Division, contesting her Filipino
citizenship but the said petition was likewise dismissed by the COMELEC.

The citizenship of private respondent was once again raised as an issue when she ran for
re-election as governor of Davao Oriental in the May 11, 1998 elections. Her candidacy was
questioned by the herein petitioner, Cirilo Valles.

ISSUE:

Whether or not Leopoldo Lopez is a Filipino citizen.

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RULING:

Yes. The Philippine law on citizenship adheres to the principle of jus

sanguinis. Thereunder, a child follows the nationality or citizenship of the parents regardless
of the place of his/her birth, as opposed to the doctrine of jus soli which determines
nationality or citizenship on the basis of place of birth.

Private respondent Rosalind Ybasco Lopez was born on May 16, 1934 in Napier
Terrace, Broome, Western Australia, to the spouses, Telesforo Ybasco, a Filipino citizen and
native of Daet, Camarines Norte, and Theresa Marquez, an Australian. Historically, this was
a year before the 1935 Constitution took into effect and at that time, what served as the
Constitution of the Philippines were the principal organic acts by which the United States
governed the country. These were the Philippine Bill of July 1, 1902 and the Philippine
Autonomy Act of August 29, 1916, also known as the Jones Law.

Among others, these laws defined who were deemed to be citizens of the Philippine
islands. The Philippine Bill of 1902 defined Philippine citizens as:

SEC. 4 xxx all inhabitants of the Philippine Islands continuing to reside therein who were
Spanish subjects on the eleventh day of April, eighteen hundred and ninety-nine, and then
resided in the Philippine Islands, and their children born subsequent thereto, shall be deemed and
held to be citizens of the Philippine Islands and as such entitled to the protection of the United
States, except such as shall have elected to preserve their allegiance to the Crown of Spain in
accordance with the provisions of the treaty of peace between the United States and Spain signed
at Paris December tenth, eighteen hundred and ninety-eight.

Private respondents father, Telesforo Ybasco, was born on January 5, 1879 in Daet,
Camarines Norte, a fact duly evidenced by a certified true copy of an entry in the Registry of
Births. Thus, under the Philippine Bill of 1902 and the Jones Law, Telesforo Ybasco was
deemed to be a Philippine citizen. By virtue of the same laws, which were the laws in force
at the time of her birth, Telesforos daughter, herein private respondent Rosalind Ybasco
Lopez, is likewise a citizen of the Philippines.

The principle of jus sanguinis, which confers citizenship by virtue of blood relationship,
was subsequently retained under the 1973 and 1987 Constitutions. Thus, the herein private
respondent, Rosalind Ybasco Lopez, is a Filipino citizen, having been born to a Filipino
father. The fact of her being born in Australia is not tantamount to her losing her Philippine
citizenship. If Australia follows the principle of jus soli, then at most, private respondent can
also claim Australian citizenship resulting to her possession of dual citizenship.

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WHEREFORE, the petition is hereby DISMISSED and the COMELEC Resolutions,

dated July 17, 1998 and January 15, 1999, respectively, in SPA No. 98-336 AFFIRMED.

Private respondent Rosalind Ybasco Lopez is hereby adjudged qualified to run for governor of
Davao Oriental. No pronouncement as to costs.

IV. Co vs HRET

G.R. Nos. 92191-92 July 30, 1991

Facts:

The petitioners come to this Court asking for the setting aside and reversal of a decision
of the House of Representatives Electoral Tribunal (HRET). The HRET declared that respondent
Jose Ong, Jr. is a natural born Filipino citizen and a resident of Laoang, Northern Samar for
voting purposes.

The congressional election for the second district of Northern Samar was held. Among
the candidates who vied for the position of representative in the second legislative district of
Northern Samar are the petitioners, Sixto Balinquit and Antonio Co and the private respondent,
Jose Ong, Jr. Respondent Ong was proclaimed the duly elected representative of the second
district of Northern Samar.

The petitioners filed election protests against the private respondent. He alleged that Jose
Ong is not a natural born citizen of the Philippines and not a resident of the second district of
Northern Samar.

The HRET found for the private respondent. A motion for reconsideration was filed by
the petitioners. This was, however, denied by the HRET in its resolution.

Hence, these petitions for certiorari.

Issue:

1. Whether or not Jose Ong, Jr. is a natural born citizen of the Philippines.

Ruling:

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Yes. In the year 1895, the private respondent’s grandfather, Ong Te, arrived in the
Philippines from China and established his residence in the municipality of Laoang, Samar. The
father of the private respondent, Jose Ong Chuan was born in China in 1905 but was brought by
Ong Te to Samar in the year 1915, he filed withthe court an application for naturalization and
was declared a Filipino citizen.In 1984, the private respondent married a Filipina named Desiree
Lim.

For the elections of 1984 and1986, Jose Ong, Jr. registered himself as a voter of Laoang,
Samar, and voted there during those elections. Under the 1973 Constitution, those born of
Filipino fathers and those born of Filipino mothers with an alien father were placed on equal
footing.

They were both considered as natural born citizens. Besides, private respondent did more
than merely exercise his right of suffrage. He has established his life here in the Philippines. On
the issue of residence, it is not required that a person should have a house in order to establish his
residence and domicile. It is enough that he should live in the municipality or in a rented house
or in that of a friend or relative. To require him to own property in order to be eligible to run for
Congress would be tantamount to a property qualification. The Constitution only requires that
the candidate meet the age, citizenship, voting and residence requirements.

WHEREFORE, the petitions are hereby DISMISSED. The questioned decision of the
House of Representatives Electoral Tribunal is AFFIRMED. Respondent Jose Ong, Jr. is
declared a natural-born citizen of the Philippines and a resident of Laoang, Northern Samar.

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V. Bengson vs HRET

G.R. No. 142840. May 7, 2001

Facts:

Respondent Cruz was a natural-born citizen of the Philippines. He was born in Tarlac in
1960 of Filipino parents. In 1985, however, Cruz enlisted in the US Marine Corps and without
the consent of the Republic of the Philippines, took an oath of allegiance to the USA.

As a Consequence, he lost his Filipino citizenship for under CA No. 63 [(An Act
Providing for the Ways in Which Philippine Citizenship May Be Lost or Reacquired (1936)]
section 1(4), a Filipino citizen may lose his citizenship by, among other, “rendering service to or
accepting commission in the armed forces of a foreign country.” Whatever doubt that remained
regarding his loss of Philippine citizenship was erased by his naturalization as a U.S. citizen in
1990, in connection with his service in the U.S. Marine Corps.

In 1994, Cruz reacquired his Philippine citizenship through repatriation under RA 2630
[(An Act Providing for Reacquisition of Philippine Citizenship by Persons Who Lost Such
Citizenship by Rendering Service To, or Accepting Commission In, the Armed Forces of the
United States (1960)]. He ran for and was elected as the Representative of the 2nd District of
Pangasinan in the 1998 elections. He won over petitioner Bengson who was then running for
reelection. Subsequently, petitioner filed a case for Quo Warranto Ad Cautelam with respondent
HRET claiming that Cruz was not qualified to become a member of the House of

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Representatives since he is not a natural-born citizen as required under Article VI, section 6 of
the Constitution.

HRET rendered its decision dismissing the petition for quo warranto and declaring Cruz
the duly elected Representative in the said election.

Issue:

1. Whether or not Cruz who became an American citizen can still be considered a natural-
born Filipino upon his reacquisition of Philippine citizenship.

Ruling:

Yes, because Filipino citizens who have lost their citizenship may however reacquire the
same in the manner provided by law. C.A. No. 63 enumerates the 3 modes by which Philippine
citizenship may be reacquired by a former citizen: by naturalization, repatriation, and direct act
of Congress.

Repatriation may be had under various statutes by those who lost their citizenship due to:
desertion of the armed forces; services in the armed forces of the allied forces in World War II;
service in the Armed Forces of the United States at any other time, marriage of a Filipino woman
to an alien; and political economic necessity.

Repatriation results in the recovery of the original nationality. This means that a
naturalized Filipino who lost his citizenship will be restored to his prior status as a naturalized
Filipino citizen. On the other hand, if he was originally a natural-born citizen before he lost his
Philippine citizenship, he will be restored to his former status as a natural-born Filipino.

As Provided by R.A. No. 2630 Sec 1 states that “Any person who had lost his Philippine
citizenship by rendering service to, or accepting commission in, the Armed Forces of the United
States, or after separation from the Armed Forces of the United States, acquired United States
citizenship, may reacquire Philippine citizenship by taking an oath of allegiance to the Republic
of the Philippines and registering the same with Local Civil Registry in the place where he
resides or last resided in the Philippines. The said oath of allegiance shall contain a renunciation
of any other citizenship.”

Having thus taken the required oath of allegiance to the Republic and having registered
the same in the Civil Registry of Magantarem, Pangasinan in accordance with the aforecited
provision, Cruz is deemed to have recovered his original status as a natural-born citizen, a status
which he acquired at birth as the son of a Filipino father. It bears stressing that the act of

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repatriation allows him to recover, or return to, his original status before he lost his Philippine
citizenship.

WHEREFORE, the petition is hereby DISMISSED.

VI. Llamansares vs Comelec

G.R. No. 221697-221670

FACTS:

Mary Grace Natividad S. Poe-Llamanzares (petitioner) was found abandoned as a

newborn infant in the Parish Church of Jaro, Iloilo by Edgardo Militar in 1968. Parental care and
custody over her was passed on by Edgardo to his relatives, Emiliano Militar and his wife.
Emiliano reported and registered Grace Poe as a foundling with the Office of the Civil Registrar
of Iloilo City. Fenando Poe, Jr. and Susan Roces adopted Grace Poe. She went to the US to be a
permanent resident therein and became a naturalized US citizen. In 2005 she came back to the
Philippines to permanently reside herein and a year after went back to the US to dispose family
belongings.
In July 18, 2006 she re-acquired Filipino citizenship and according to Poe in her 2013
COC for Senator, before the May 13, 2013 election, she has been a resident of the Philippines for

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6 years and 6 months (reckoned from year 2006 when she re-acquired her Filipino citizenship
under RA 9225).
Poe filed her COC for Presidency for the May 9, 2016 elections (hence, computing from
May, 2013, she has been a resident in the Philippines for 9 years and 6 months only). However,
in her COC, Poe declared that she is a natural born and her residence in the Philippine up to the
day before election would be 10 years and 11 months counted from May 24, 2005(when she
returned from the US to the Philippines for good).

ISSUE:

1. Whether or not Poe, a foundling, a natural-born citizen.

2. Whether or not Poe is qualified to be a candidate for President in the National and Local
Election.

RULINGS:
1. Yes. Foundlings are as a class, natural born citizens. The amendment to
the Constitution proposed by constitutionalist Rafols to include foundlings as natural born
citizens was not carried out, not because there was any objection to the notion that persons of
unknown parentage are not citizens, but only because their number was not enough to merit
specific mention. There was no intent or language that would permit discrimination against
foundlings. On the contrary, all three Constitutions guarantee the basic right to equal protection
of the laws.
Likewise, domestic laws on adoption support the principle that foundlings are Filipinos.
These laws do not provide that adoption confers citizenship upon the adoptee, rather, the adoptee
must be Filipino in the first place to be adopted.
Recent legislation all expressly refer to “Filipino children” and include foundlings as
among Filipino children who may be adopted.
Generally accepted principles of international law
The common thread of the Universal Declaration of Human Rights, the Convention on
the Rights of the Child and the International Convent on Civil and Political Rights obligates the
Philippines to grant nationality from birth and to ensure that no child is stateless. The principles
stated in the: Hague Convention on Certain Questions Relation to the Conflict of Nationality
laws (that a foundling is presumed to have the nationality of the country of birth) and Convention
on the Reduction of Statelessness (foundling is presumed born of citizens of the country where
he is found)

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Are binding in the Philippines although we are not signatory to these conventions. There is a
generally accepted principle of international law to presume foundlings as having been born and
a national of the country in which it is found.

2. Yes. Poe’s repatriation resulted to reacquisition of natural born citizenship. A natural born
citizen before he lost his Philippine nationality will be restored to his former status as natural
born Filipino after repatriation.
She also satisfied the 10 year residency requirement. She will have been a resident
for 10 years and 11 months on the day of the election.
There is overwhelming evidence that leads to no to other conclusion that Poe decided to
permanently abandon her US residence and reside in the Philippines as early as May 24, 2005.
Poe presented voluminous evidence showing that she and her family abandoned their US
domicile and relocated to the Philippines for good. These evidence include former US passport
showing her arrival on May 24, 2005 and her return to the Philippines every time she travelled
abroad, email correspondences with freight company to arrange for the shipment of household
items as well as with the pet Bureau; school records of her children showing enrolment in the
Philippine to the Philippine schools starting on June 2005 etc. These evidence, coupled with her
eventual application to reacquire Philippine citizenship is clear that when she returned in May
2005, it was for good.
Poe was able to prove that her statement in her 2013 COC was only a mistake in good
faith. As explained by Grace Poe, she misunderstood the date required in the 2013 COC as the
period of residence as of the day she submitted that COC in 2012. She said that she reckoned
residency from April-May 2006 which was the period when the U.S. house was sold and her
husband returned to the Philippines. In that regard, she was advised by her lawyers in 2015 that
residence could be counted from 25 May 2005. Such a mistake could be given in evidence
against her but it was by no means conclusive considering the overwhelming evidence submitted
by Poe.

Wherefore Petitioner MARY GRACE NATIVIDAD SONORA POE-LLAMANZARES

is DECLARED QUALIFIED to be a candidate for President in the National and Local Elections
of 9 May 2016.

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VII. Cabiling vs et. al. Commissioner

G.R. NO. 183133 July 26, 2010

Facts:

Records reveal that petitioners Felix, Jr., Balgamelo and Valeriano were all born under
aegis of the 1935 Philippine Constitution in the years 1948, 1951, and 1957, respectively. They
were all raised in the Philippines and have resided in this country for almost sixty (60) years;
they spent their whole lives, studied and received their primary and secondary education in the

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country; they do not speak nor understand the Chinese language, have not set foot in Taiwan, and
do not know any relative of their father; they have not even traveled abroad; and they have
already raised their respective families in the Philippines.

During their age of minority, they secured from the Bureau of Immigration their Alien
Certificates of Registration (ACRs). Immediately upon reaching the age of twenty-one, they
claimed Philippine citizenship in accordance with Section 1(4), Article IV, of the 1935
Constitution, which provides that (t)hose whose mothers are citizens of the Philippines and, upon
reaching the age of majority, elect Philippine citizenship are citizens of the Philippines.

Felix, Jr. executed his affidavit of election of Philippine citizenship and took his oath of
allegiance before then Judge Jose L. Gonzalez, Municipal Judge, Surigao, Surigao del Norte.
Balgamelo did the same before Atty. Patrocinio C. Filoteo, Notary Public, Surigao City, Surigao
del Norte. In 1978, Valeriano took his oath of allegiance before then Judge Salvador C. Sering,
City Court of Surigao City, the fact of which the latter attested to in his Affidavit of 7 March
2005. Having taken their oath of allegiance as Philippine citizens, petitioners, however, failed to
have the necessary documents registered in the civil registry as required under Section 1 of
Commonwealth Act No. 625 (An Act Providing the Manner in which the Option to Elect
Philippine Citizenship shall be Declared by a Person whose Mother is a Filipino Citizen).

It was only on 27 July 2005 or more than thirty (30) years after they elected Philippine
citizenship that Balgamelo and Felix, Jr. did so. On the other hand, there is no showing that
Valeriano complied with the registration requirement. Individual certifications all dated 3
January 2005 issued by the Office of the City Election Officer, Commission on Elections,
Surigao City, show that all of them are registered voters of Barangay Washington, Precinct No.
0015A since June 1997, and that records on previous registrations are no longer available
because of the mandatory general registration every ten (10) years.

Moreover, aside from exercising their right of suffrage, Balgamelo is one of the
incumbent Barangay Kagawads in BarangayWashington, Surigao City. Records further reveal
that Lechi Ann and Arceli were born also in Surigao City in 1953and 1959, respectively. The
Office of the City Civil Registrar issued a Certification to the effect that the documents showing
that Arceli elected Philippine citizenship on 27 January 1986 were registered in its Office on 4
February 1986. However, no other supporting documents appear to show that Lechi Ann initially
obtained an ACR nor that she subsequently elected Philippine citizenship upon reaching the age
of majority. Likewise, no document exists that will provide information on the citizenship of
Nicolas and Isidro.

Issue:

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Whether or not the omission negates their rights to Filipino citizenship as children of a
Filipino mother, and erases the years lived and spent as Filipinos.

Ruling:

No. The 1935 Constitution declares as citizens of the Philippines those whose mothers
are citizens of the Philippines and elect Philippine citizenship upon reaching the age of majority.
The mandate states: Section 1. The following are citizens of the Philippines: (4) Those whose
mothers are citizens of the Philippines and, upon reaching the age of majority, elect Philippine
citizenship.

In 1941, Commonwealth Act No. 625 was enacted. It laid down the manner of electing
Philippine citizenship, to wit: Section 1. The option to elect Philippine citizenship in accordance
with subsection (4), Section 1, Article IV, of the Constitution shall be expressed in a statement to
be signed and sworn to by the party concerned before any officer authorized to administer oaths,
and shall be filed with the nearest civil registry.

The said party shall accompany the aforesaid statement with the oath of allegiance to the
Constitution and the Government of the Philippines. The statutory formalities of electing
Philippine citizenship are: (1) a statement of election under oath; (2) an oath of allegiance to the
Constitution and Government of thePhilippines; and (3) registration of the statement of election
and of the oath with the nearest civil registry. We rule that under the facts peculiar to the
petitioners, the right to elect Philippine citizenship has not been lost and they should be allowed
to complete the statutory requirements for such election.

Having a Filipino mother is permanent. It is the basis of the right of the petitioners to
elect Philippine citizenship. Petitioners elected Philippine citizenship in form and substance. The
failure to register the election in the civil registry should not defeat the election and resultantly
negate the permanent fact that they have a Filipino mother. The lacking requirements may still be
complied with subject to the imposition of appropriate administrative penalties, if any. The
documents they submitted supporting their allegations that they have already registered with the
civil registry, although belatedly, should be examined for validation purposes by the appropriate
agency, in this case, the Bureau of Immigration. Other requirements embodied in the
administrative orders and other issuances of the Bureau of Immigration and the Department of
Justice shall be complied with within a reasonable time.

WHEREFORE, with respect to petitioners Balgamelo Cabiling Ma, Felix Cabiling Ma,
Jr., and Valeriano Cabiling Ma. Petitioners are given ninety (90) days from notice within which
to COMPLY with the requirements of the Bureau of Immigration. The Bureau of Immigration
shall ENSURE that all requirements, including the payment of their financial obligations to the
state, if any, have been complied with subject to the imposition of appropriate administrative

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fines; REVIEW the documents submitted by the petitioners; and ACT thereon in accordance
with the decision of this Court.

VIII. Frivaldo vs COMELEC

G.R. No. 87193 June 23, 1989

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Facts:

Petitioner Juan G. Frivaldo was proclaimed governor-elect of the province of Sorsogon

on January 22, 1988, and assumed office in due time. The League of Municipalities, Sorsogon
Chapter (hereafter, League), represented by its President, Salvador Estuye, who was also suing in
his personal capacity, filed with the Commission on Elections a petition for the annulment of
Frivaldo; election and proclamation on the ground that he was not a Filipino citizen, having been
naturalized in the United States on January 20, 1983.

Frivaldo admitted that he was naturalized in the United States as alleged but pleaded the
special and affirmative defenses that he had sought American citizenship only to protect himself
against President Marcos. His naturalization, he said, was "merely forced upon himself as a
means of survival against the unrelenting persecution by the Martial Law Dictator's agents
abroad." He added that he had returned to the Philippines after the EDSA revolution to help in
the restoration of democracy.

He also argued that the challenge to his title should be dismissed, being in reality a quo
warranto petition that should have been filed within ten days from his proclamation, in
accordance with Section 253 of the Omnibus Election Code. The League, moreover, was not a
proper party because it was not a voter and so could not sue under the said section.

Frivaldo moved for a preliminary hearing on his affirmative defenses but the respondent
Commission on Elections decided instead by its Order of January 20, 1988, to set the case for
hearing on the merits. His motion for reconsideration was denied in another Order dated
February 21, 1988. He then came to this Court in a petition for certiorari and prohibition to ask
that the said orders be set aside on the ground that they had been rendered with grave abuse of
discretion. Pending resolution of the petition, we issued a temporary order against the hearing on
the merits scheduled by the COMELEC and at the same time required comments from the
respondents.

In their Comment, the private respondents reiterated their assertion that Frivaldo was a
naturalized American citizen and had not reacquired Philippine citizenship on the day of the
election on January 18, 1988. He was therefore not qualified to run for and be elected governor.
They also argued that their petition in the Commission on Elections was not really for quo
warranto under Section 253 of the Omnibus Election Code.

The ultimate purpose was to prevent Frivaldo from continuing as governor, his candidacy
and election being null and void ab initio because of his alienage. Even if their petition were to
be considered as one for quo warranto, it could not have been filed within ten days from
Frivaldo's proclamation because it was only in September 1988 that they received proof of his
naturalization. And assuming that the League itself was not a proper party, Estuye himself, who

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was suing not only for the League but also in his personal capacity, could nevertheless institute
the suit by himself alone.

Speaking for the public respondent, the Solicitor General supported the contention that
Frivaldo was not a citizen of the Philippines and had not repatriated himself after his
naturalization as an American citizen. As an alien, he was disqualified from public office in the
Philippines. His election did not cure this defect because the electorate of Sorsogon could not
amend the Constitution, the Local Government Code, and the Omnibus Election Code. He
agreed that they were also asking for the termination of Frivaldo's incumbency as governor of
Sorsogon on the ground that he was not a Filipino.

Issue:

1. Whether or not petitioner Juan G. Frivaldo was a citizen of the Philippines at the time of
his election as provincial governor of Sorsogon.

Ruling:

NO. Section 117 of the Omnibus Election Code provides that a qualified voter must be,
among other qualifications, a citizen of the Philippines, this being an indispensable requirement
for suffrage under Article V, Section 1, of the Constitution. In the certificate of candidacy he
filed on November 19, 1987, Frivaldo described himself as a "natural-born" citizen of the
Philippines, omitting mention of any subsequent loss of such status. The evidence shows,
however, that he was naturalized as a citizen of the United States in 1983 per the following
certification from the United States District Court, Northern District of California, as duly
authenticated by Vice Consul Amado P. Cortez of the Philippine Consulate General in San
Francisco, California, U.S.A.

The Court sees no reason not to believe that the petitioner was one of the enemies of the
Marcos dictatorship. Even so, it cannot agree that as a consequence thereof he was coerced into
embracing American citizenship. His feeble suggestion that his naturalization was not the result
of his own free and voluntary choice is totally unacceptable and must be rejected outright. This
Court will not permit the anomaly of a person sitting as provincial governor in this country while
owing exclusive allegiance to another country.

The fact that he was elected by the people of Sorsogon does not excuse this patent
violation of the salutary rule limiting public office and employment only to the citizens of this
country. The qualifications prescribed for elective office cannot be erased by the electorate
alone. The will of the people as expressed through the ballot cannot cure the vice of ineligibility,
especially if they mistakenly believed, as in this case, that the candidate was qualified.

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Obviously, this rule requires strict application when the deficiency is lack of citizenship.
If a person seeks to serve in the Republic of the Philippines, he must owe his total loyalty to this
country only, abjuring and renouncing all fealty and fidelity to any other state. It is true as the
petitioner points out that the status of the natural-born citizen is favored by the Constitution and
our laws, which is all the more reason why it should be treasured like a pearl of great price.

But once it is surrendered and renounced, the gift is gone and cannot be lightly restored.
This country of ours, for all its difficulties and limitations, is like a jealous and possessive
mother. Once rejected, it is not quick to welcome back with eager arms its prodigal if repentant
children.

The returning renegade must show, by an express and unequivocal act, the renewal of his
loyalty and love. Petitioner JUAN G. FRIVALDO is hereby declared not a citizen of the
Philippines and therefore disqualified from serving as Governor of the Province of Sorsogon.
Accordingly, he is ordered to vacate his office and surrender the same to the duly elected Vice-
Governor of the said province once this decision becomes final and executory.

Wherefore the petition is hereby dismissed.

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IX. Tabasa vs CA

G.R. No. 125793 August 29, 2006

Facts:

The facts as culled by the CA from the records show that petitioner Joevanie Arellano
Tabasa was a natural-born citizen of the Philippines. In 1968, when petitioner was seven years
old, his father, Rodolfo Tabasa, became a naturalized citizen of the United States. By derivative
naturalization (citizenship derived from that of another as from a person who holds citizenship
by virtue of naturalization, petitioner also acquired American citizenship. Petitioner arrived in
the Philippines on August 3, 1995, and was admitted as a balikbayan for one year.

Thereafter, petitioner was arrested and detained by agent Wilson Soluren of the BID in
Baybay, Malay, Aklan; subsequently, he was brought to the BID Detention Center in Manila.

Petitioner was investigated by Special Prosecutor Atty. Edy D. Donato at the Law and
Investigation Division of the BID and on the same day, Tabasa was accused of violating Section
8, Chapter 3, Title 1, Book 3 of the 1987 Administrative Code. At the time Tabasa filed said
petition, he was already 35 years old.

The CA ordered the respondent Bureau to produce the person of the petitioner on June 3,
1996 and show the cause of petitioners detention, and restrained the Bureau from summarily
deporting him. On June 3, 1996, the BID presented Tabasa before the CA; and on June 6, 1996,
the CA granted both parties ten (10) days within which to file their memoranda, after which the
case would be considered submitted for decision.

Meanwhile, the Commissioner of Immigration granted the petitioners temporary release

on bail on a PhP 20,000.00 cash bond. However, on June 13, 1996, petitioner filed a
Supplemental Petition alleging that he had acquired Filipino citizenship by repatriation in
accordance with Republic Act No. 8171 (RA 8171), and that because he is now a Filipino
citizen, he cannot be deported or detained by the respondent Bureau.

Issue:

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1. Whether or not Jose Ong, Jr. is a citizen of the Philippines.

Ruling:

Yes. In the year 1895, the private respondent’s grandfather, Ong Te, arrived in the
Philippines from China and established his residence in the municipality of Laoang, Samar. The
father of the private respondent, Jose Ong Chuan was born in China in 1905 but was brought by
Ong Te to Samar in the year 1915, he filed with the court an application for naturalization and
was declared a Filipino citizen.

In 1984, the private respondent married a Filipina named Desiree Lim. For the elections
of 1984 and1986, Jose Ong, Jr. registered himself as a voter of Laoang, Samar, and voted there
during those elections.

Under the 1973 Constitution, those born of Filipino fathers and those born of Filipino
mothers with an alien father were placed on equal footing. They were both considered as natural
born citizens. Besides, private respondent did more than merely exercise his right of suffrage.

He has established his life here in the Philippines. On the issue of residence, it is not
required that a person should have a house in order to establish his residence and domicile. It is
enough that he should live in the municipality or in a rented house or in that of a friend or
relative. To require him to own property in order to be eligible to run for Congress would be
tantamount to a property qualification. The Constitution only requires that the candidate meet the
age, citizenship, voting and residence requirements.

WHEREFORE, this petition for review is DISMISSED, and the Decision of the Court of
Appeals is AFFIRMED.

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X. Mercado vs Manzano

G.R. No. 135083. May 26, 1999

Facts:
Petitioner Ernesto Mercado and Private respondent Eduardo Manzano are candidates for
the position of Vice-Mayor of Makati City in the May, 1998 elections. Private respondent was
the winner of the said election but the proclamation was suspended due to the petition of Ernesto
Mamaril regarding the citizenship of private respondent.
Mamaril alleged that the private respondent is not a citizen of the Philippines but of the
United States. COMELEC granted the petition and disqualified the private respondent for being
a dual citizen, pursuant to the Local Government code that provides that persons who possess
dual citizenship are disqualified from running any public position. Private respondent filed a
motion for reconsideration which remained pending until after election.
Petitioner sought to intervene in the case for disqualification. COMELEC reversed the
decision and declared private respondent qualified to run for the position. Pursuant to the ruling
of the COMELEC, the board of canvassers proclaimed private respondent as vice mayor. This
petition sought the reversal of the resolution of the COMELEC and to declare the private
respondent disqualified to hold the office of the vice mayor of Makati.

Issue:
1. Whether or Not private respondent is qualified to hold office as Vice-Mayor.

Ruling:
Yes. Dual citizenship is different from dual allegiance. The former arises when, as a
result of the concurrent application of the different laws of two or more states, a person is
simultaneously considered a national by the said states. For instance, such a situation may arise
when a person whose parents are citizens of a state which adheres to the principle of jus
sanguinis is born in a state which follows the doctrine of jus soli. Private respondent is

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considered as a dual citizen because he is born of Filipino parents but was born in San Francisco,
USA.
Such a person, ipso facto and without any voluntary act on his part, is concurrently
considered a citizen of both states. Considering the citizenship clause (Art. IV) of our
Constitution, it is possible for the following classes of citizens of the Philippines to posses dual
citizenship: (1) Those born of Filipino fathers and/or mothers in foreign countries which follow
the principle of jus soli; (2) Those born in thePhilippines of Filipino mothers and alien fathers if
by the laws of their fathers’ country such children are citizens of that country; (3) Those who
marry aliens if by the laws of the latter’s country the former are considered citizens, unless by
their act or omission they are deemed to have renounced Philippine citizenship. Dual allegiance,
on the other hand, refers to the situation in which a person simultaneously owes, by some
positive act, loyalty to two or more states. While dual citizenship is involuntary, dual allegiance
is the result of an individual’s volition.

By filing a certificate of candidacy when he ran for his present post, private respondent
elected Philippine citizenship and in effect renounced his American citizenship. The filing of
such certificate of candidacy sufficed to renounce his American citizenship, effectively removing
any disqualification he might have as a dual citizen.

By declaring in his certificate of candidacy that he is a Filipino citizen; that he is not a

permanent resident or immigrant of another country; that he will defend and support the
Constitution of the Philippines and bear true faith and allegiance thereto and that he does so
without mental reservation, private respondent has, as far as the laws of this country are
concerned, effectively repudiated his American citizenship and anything which he may have said
before as a dual citizen. On the other hand, private respondent’s oath of allegiance to the
Philippine, when considered with the fact that he has spent his youth and adulthood, received his
education, practiced his profession as an artist, and taken part in past elections in this country,
leaves no doubt of his election of Philippine citizenship.

WHEREFORE, the petition for certiorari is DISMISSED for lack of merit.

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XI. Jacot vs Dal and COMELEC

G.R. No. 17984 November 27, 2008

FACTS:

Petitioner was a natural born citizen of the Philippines, who became a naturalized citizen
of the US on 13 December 1989. Petitioner sought to reacquire his Philippine citizenship under
Republic Act No. 9225, otherwise known as the Citizenship Retention and Re-Acquisition Act.
He filed a request for the administration of his Oath of Allegiance to the Republic of the
Philippines with the Philippine Consulate General (PCG) of Los Angeles, California.

The Los Angeles PCG issued on 19 June 2006 an Order of Approval of petitioners
request, and on the same day, petitioner took his Oath of Allegiance to the Republic of
thePhilippines before Vice Consul Edward C. Yulo. On 27 September 2006, the Bureau of
Immigration issued Identification Certificate No. 06-12019 recognizing petitioner as a citizen of
the Philippines. Six months after, on 26 March 2007, petitioner filed his Certificate of Candidacy
for the Position of Vice-Mayor of the Municipality of Catarman, Camiguin.

Respondent Rogen T. Dal filed a Petition for Disqualification[8] before the COMELEC
Provincial Office in Camiguin against petitioner, arguing that the latter failed to renounce his US
citizenship, as required under Section 5(2) of Republic Act No. 9225. On 12 June 2007, the
COMELEC Second Division finally issued its Resolution disqualifying the petitioner from
running for the position of Vice-Mayor of Catarman,Camiguin, for failure to make the requisite
renunciation of his US citizenship. The COMELEC Second Division explained that the
reacquisition of Philippine citizenship under Republic Act No. 9225 does not automatically
bestow upon any person the privilege to run for any elective public office. It additionally ruled

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that the filing of a Certificate of Candidacy cannot be considered as a renunciation of foreign

citizenship.

ISSUE:

1. Whether or not Nestor Jacot effectively renounce his US citizenship.

RULING:

No. It bears to emphasize that the oath of allegiance is a general requirement for all those
who wish to run as candidates in Philippine elections; while the renunciation of foreign
citizenship is an additional requisite only for those who have retained or reacquired Philippine
citizenship under Republic Act No. 9225 and who seek elective public posts, considering their
special circumstance of having more than one citizenship.

Petitioner also makes much of the fact that he received the highest number of votes for the
position of Vice-Mayor of Catarman during the 2007 local elections. The fact that a candidate,
who must comply with the election requirements applicable to dual citizens and failed to do so,
received the highest number of votes for an elective position does not dispense with, or amount
to a waiver of, such requirement.

The will of the people as expressed through the ballot cannot cure the vice of ineligibility,
especially if they mistakenly believed that the candidate was qualified. The rules on citizenship
qualifications of a candidate must be strictly applied. If a person seeks to serve the Republic of
thePhilippines, he must owe his loyalty to this country only, abjuring and renouncing all fealty
and fidelity to any other state.The application of the constitutional and statutory provisions on
disqualification is not a matter of popularity.

WHEREFORE, the instant appeal is DISMISSED. Petitioner is DISQUALIFIED to run for

the position of Vice-Mayor of Catarman, Camiguin in the 14 May 2007 National and Local
Elections, and if proclaimed, cannot assume the Office of Vice-Mayor of said municipality by
virtue of such disqualification. Costs against petitioner.

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XII. AASJS Member Calilung vs Datumanong

G.R NO. 160869 May 11, 2007

Facts:

Petitioner filed the instant petition against respondent, then Secretary of Justice Simeon
Datumanong, the official tasked to implement laws governing citizenship. Petitioner prays that a
writ of prohibition be issued to stop respondent from implementing Republic Act No. 9225,
entitled An Act Making the Citizenship of Philippine Citizens Who Acquire Foreign Citizenship
Permanent, Amending for the Purpose Commonwealth Act No. 63, As Amended, and for Other
Purposes.

Petitioner avers that Rep. Act No. 9225 is unconstitutional as it violates Section 5,
Article IV of the 1987 Constitution that states, Dual allegiance of citizens is inimical to the
national interest and shall be dealt with by law. Petitioner contends that Rep. Act No. 9225
cheapens Philippine citizenship.

He avers that Sections 2 and 3 of Rep. Act No. 9225, together, allow dual allegiance and
not dual citizenship. Petitioner maintains that Section 2 allows all Filipinos, either natural-born
or naturalized, who become foreign citizens, to retain their Philippine citizenship without losing
their foreign citizenship. Section 3 permits dual allegiance because said law allows natural-born
citizens of the Philippines to regain their Philippine citizenship by simply taking an oath of
allegiance without forfeiting their foreign allegiance.

The Constitution, however, is categorical that dual allegiance is inimical to the national
interest. The Office of the Solicitor General (OSG) claims that Section 2 merely declares as a

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state policy that Philippine citizens who become citizens of another country shall be deemed not
to have lost their Philippine citizenship.

The OSG further claims that the oath in Section 3 does not allow dual allegiance since
the oath taken by the former Filipino citizen is an effective renunciation and repudiation of his
foreign citizenship. The fact that the applicant taking the oath recognizes and accepts the
supreme authority of the Philippines is an unmistakable and categorical affirmation of his
undivided loyalty to the Republic.

Issue:

1. Whether or not does this Court have jurisdiction to pass upon the issue of dual
allegiance.

Ruling:

It is clear that the intent of the legislature in drafting Rep. Act No. 9225 is to do away
with the provision in Commonwealth Act No. 63 which takes away Philippine citizenship from
natural-born Filipinos who become naturalized citizens of other countries. What Rep. Act No.
9225 does is allow dual citizenship to natural-born Filipino citizens who have lost Philippine
citizenship by reason of their naturalization as citizens of a foreign country. On its face, it does
not recognize dual allegiance. By swearing to the supreme authority of the Republic, the person
implicitly renounces his foreign citizenship.

Plainly, from Section 3, Rep. Act No. 9225 stayed clear out of the problem of dual
allegiance and shifted the burden of confronting the issue of whether or not there is dual
allegiance to the concerned foreign country. What happens to the other citizenship was not made
a concern of Rep. Act No. 9225. To begin with, Section 5, Article IV of the Constitution is a
declaration of a policy and it is not a self-executing provision.

The legislature still has to enact the law on dual allegiance. In Sections 2 and 3 of Rep.
Act No. 9225, the framers were not concerned with dual citizenship per se, but with the status of
naturalized citizens who maintain their allegiance to their countries of origin even after their
naturalization.Congress was given a mandate to draft a law that would set specific parameters of
what really constitutes dual allegiance.Until this is done, it would be premature for the judicial
department, including this Court, to rule on issues pertaining to dual allegiance.

WHEREFORE, the petition is hereby DISMISSED for lack of merit

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