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E. NATIONALITY AND DOMICILE
1. DJUMANTAN V. DOMINGO
 Never was the marriage of petitioner to
Banez disclosed to the immigration
authorities in her applications for
temporary visitor's visa and for
permanent residency.
 Generally, the right of the President to
expel or deport aliens whose presence is
deemed inimical to the public interest is
as absolute and unqualified as the right
to prohibit and prevent their entry into
the country, this right is based on the
fact that since the aliens are not part of
the nation, their admission into the
territory is a matter of pure permission
and simple tolerance which creates no
obligation on the part of the government
to permit them to stay.
 There is no law guaranteeing aliens
married to Filipino citizens the right to
be admitted, much less to be given
permanent residency, in the Philippines.
The fact of marriage by an alien to a
citizen does not withdraw her from the
operation of the immigration laws
governing the admission and exclusion
of aliens. Marriage of an alien woman to
a Filipino husband does not ipso facto
make her a Filipino citizen and does not
excuse her from her failure to depart
from the country upon the expiration of
her extended stay here as an alien.
 Under Section 9 of the Immigration Act
of 1940, it is not mandatory for the CID
to admit any alien who applies for a
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visitor's visa. Once admitted into the
country, the alien has no right to an
indefinite stay. Under Section 13 of the
law, an alien allowed to stay temporarily
may apply for a change of status and
"may be admitted" as a permanent
resident. Among those considered
qualified to apply for permanent
residency if the wife or husband of a
Philippine citizen (Immigration Act of
1940, Sec. 13[a]). The entry of aliens
into the country and their admission as
immigrants is not a matter of right, even
if they are legally married to Filipino
citizens. Indonesian wife can be
deported.
2. TUAN ANH NGUYEN V. INS
 When the citizen parent of the child born
abroad and out of wedlock is the child’s
mother, the requirements for the
transmittal of citizenship are described
in 1409(c): c. Notwithstanding the
provision of subsection (a) of this
section, a person born, after December
23, 1952, outside the United States and
out wedlock shall be held to have
acquired at birth the nationality status of
his mother, if the mother had the
nationality of the United States at the
time of such person’s birth, and if the
mother had previously been physically
present in the United States or one of its
outlying possessions for a continuos
period of one year. Specifically, the
imposition of the requirement for a
paternal relationship, but not a maternal

one, is justified by two important
governmental objectives.
 The first governmental interest to be
served is the importance of assuring that
a biological parent - child relationship
exists. In the case of the mother, the
relation is verifiable from the birth itself.
 The second important governmental
interest furthered in a substantial manner
by 1409(a)(4) is the determination to
ensure that the child and the citizen
parent have some demonstrated
opportunity, or potential to develop not
just a relationship that is recognzed by
the law but one that consist of the real
everyday ties that provide a certain
connection between child and citizen
parent and in turn the United States. In
the case of citizen mother and a child
born oversees, the opportunity for a
meaningful relationship between citizen
parent and child inheres in the very
event of birth, an event so often critical
to our constitutional and statutory
understandings of citizenship.
 Section 1409(a) thus imposes a set of
requirements on the children of citizen
fathers born abroad and out of wedlock
to a noncitizen mother that are not
imposed under like circumstances when
the citizen parent is the mother. All
concede the requirements of 1409(a)(3)
and (a)(4), relating to a citizen father’s
acknowledgement of a child while he is
under 18, were not satisfied in this case.
As an individual seeking citizenship
under 1409(a) must meet all of its
preconditions, the failure to satisfy
1409(a)(4) renders Nguyen ineligible for
citizenship. Before considering the
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important governmental interests
advanced by the statute, two
observations concerning the operation of
the provision are in order. First, a citizen
mother expecting a child and living
abroad has the right to reenter the United
States so the child can be born here and
be a 14th amendment citizen. From one
perspective the statute simply ensures
equivalence between two expectant
mothers who are citizens abroad if one
chooses to reenter for the child’s birth
and the other chooses not to return, or
does not have the means to do so. This
equivalence is not a factor if the single
citizen parent living abroad is the father.
For, unlike the unmarried mother, the
unmarried father as a general rule cannot
control where the child will be born.
 Second, although 1409(a)(4) requires
certain conduct to occur before the child
of a citizen father born out of wedlock
and abroad reaches 18 years of age, it
imposes no limitation on when an
individual who qualifies under the
statute can claim citizenship. The
statutory treatment of citizenship is
identical in this respect wether the
citizen parent is the mother of the father.
A person born to a citizen parent of
either gender may assert citizenship,
assuming compliance with statutory
preconditions regardless of his or her
age. And while the conditions necessary
for a citizen mother to transmit
citizenship under 1409(c) exist at birth,
citizen father and/or their children have
18 years to satisfy the requirements of
1409(a)(4).

 Statutory distinction relevant in this
case, is that 1409(a)(4) requires one of
three affirmative steps to be taken if the
citizen parent is the father, but not if the
citizen parent is the mother: legitimation,
a declaration of paternity under oath by
the father, or a court order of paternity.
Congress ‘ decision to impose
requirements on unmarried fathers that
differ from those on unmarried mothers
is based on the significant difference
between the respective relationships to
the potential citizen at the time of birth.
 Specifically, the imposition of the
requirement for a paternal relationship,
but not a maternal one, is justified by
two important governmental
objectives.The first governmental
interest to be served is the importance of
assuring that a biological parent - child
relationship exists. In the case of the
mother, the relation is verifiable from
the birth itself.The second important
governmental interest furthered in a
substantial manner by 1409(a)(4) is the
determination to ensure that the child
and the citizen parent have some
demonstrated opportunity, or potential to
develop not just a relationship that is
recognzed by the law but one that
consist of the real everyday ties that
provide a certain connection between
child and citizen parent and in turn the
United States. In the case of citizen
mother and a child born oversees, the
opportunity for a meaningful
relationship between citizen parent and
child inheres in the very event of birth,
an event so often critical to our
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constitutional and statutory
understandings of citizenship.
3. SCHNEIDER V. RUSK
 352(a)(1) is discriminatory, and
therefore violative of due process under
the Fifth Amendment of the
Constitution, since no restriction against
the length of foreign residence applies to
native-born citizens, though some
members of that majority believe that
Congress lacks constitutional power to
effect involuntary divestiture of
citizenship.
 Section 352(a)(1) of the Immigration
and Nationality' Act of 1952, provides:
 “(a) A person who has become a
national by naturalization shall lose his
nationality by --"(1) having a continuous
residence for three years in the territory
of a foreign state of which he was
formerly a national or in which the place
of his birth is situated, except as
provided in section 353 of this title,
whether such residence commenced
before or after the effective date of this
Act. . . ."
 While the Fifth Amendment contains no
equal protection clause, it does forbid
discrimination that is so unjustifiable as
to be violative of due process. A native-
born citizen is free to reside abroad
indefinitely without suffering loss of
citizenship. The discrimination aimed at
naturalized citizens drastically limits
their rights to live and work abroad in a
way that other citizens may. It creates
indeed a second-class citizenship. Living
abroad, whether the citizen be
naturalized or native born, is no badge of
lack of allegiance, and in no way
evidences a voluntary renunciation of
nationality and allegiance. It may indeed

be compelled by family, business, or
other legitimate reasons
4. TROP V. DULLES
 Section 401(g), the statute that decrees
the forfeiture of this petitioner's
citizenship, is based directly on a Civil
War statute, which provided that a
deserter would lose his "rights of
citizenship." The meaning of this phrase
was not clear. Citizenship is not subject
to the general powers of the National
Government, and therefore cannot be
divested in the exercise of those powers.
The right may be voluntarily
relinquished or abandoned either by
express language or by language and
conduct that show a renunciation of
citizenship.
 Under these principles, this petitioner
has not lost his citizenship. Desertion in
wartime, though it may merit the
ultimate penalty, does not necessarily
signify allegiance to a foreign state.
Section 401(g) is not limited to cases of
desertion to the enemy, and there is no
such element in this case. This soldier
committed a crime for which he should
be and was punished, but he did not
involve himself in any way with a
foreign state. There was no dilution of
his allegiance to this country.
 Use of denationalization as a punishment
is barred by the Eighth Amendment.
There may be involved no physical
mistreatment, no primitive torture. There
is, instead, the total destruction of the
individual's status in organized society.
It is a form of punishment more
primitive than torture, for it destroys for
the individual the political existence that
was centuries in the development. The
punishment strips the citizen of his status
in the national and international political
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community. His very existence is at the
sufferance of the country in which he
happens to find himself. While any one
country may accord him some rights
and, presumably, as long as he remained
in this country, he would enjoy the
limited rights of an alien, no country
need do so, because he is stateless.
Furthermore, his enjoyment of even the
limited rights of an alien might be
subject to termination at any time by
reason of deportation. In short, the
expatriate has lost the right to have
rights.
 This punishment is offensive to cardinal
principles for which the Constitution
stands. The civilized nations of the
world are in virtual unanimity that
statelessness is not to be imposed as
punishment for crime. It is true that
several countries prescribe expatriation
in the event that their nationals engage in
conduct in derogation of native
allegiance.
5. CALILUNG V. DATUMANONG
 It is clear that the intent of the legislature
in drafting RA 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 RA 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 Sec. 3,

RA 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 RA 9225.
 Pursuant to Sec. 5, Article IV of the
1987 Constitution, dual allegiance shall
be dealt with by law. Thus, until a law
on dual allegiance is enacted by
Congress, the Supreme Court is without
any jurisdiction to entertain issues
regarding dual allegiance. 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 RA
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.
6. MACALINTAL V. COMMISSION ON
ELECTIONS
 Section 5(d) of R.A. No. 9189 is not
violative of Art. V, Sec. 1 of the
Constitution.
 Section 5(d) of R.A. No. 9189, entitled
“An Act Providing for a System of
Overseas Absentee Voting by Qualified
Citizens of the Philippines Abroad,
Appropriating Funds Therefor, and for
Other Purposes,” provides:
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 Sec. 5. Disqualifications.—The
following shall be disqualified from
voting under this Act: xxxxxxxxx d) An
immigrant or a permanent resident who
is recognized as such in the host country,
unless he/she executes, upon
registration, an affidavit prepared for the
purpose by the Commission declaring
that he/she shall resume actual physical
permanent residence in the Philippines
not later than three (3) years from
approval of his/her registration under
this Act. Such affidavit shall also state
that he/she has not applied for
citizenship in another country. Failure to
return shall be cause for the removal of
the name of the immigrant or permanent
resident from the National Registry of
Absentee Voters and his/her permanent
disqualification to vote in absentia.
 It was clearly shown from the said
discussions that the Constitutional
Commission intended to enfranchise as
much as possible all Filipino citizens
abroad who have not abandoned their
domicile of origin, which is in the
Philippines. The Commission even
intended to extend to young Filipinos
who reach voting age abroad whose
parents’ domicile of origin is in the
Philippines, and consider them qualified
as voters for the first time.
 It is in pursuance of that intention that
the Commission provided for Section 2
immediately after the residency
requirement of Section 1. By the
doctrine of necessary implication in
statutory construction, which may be
applied in construing constitutional
provisions, the strategic location of
Section 2 indicates that the
Constitutional Commission provided for
an exception to the actual residency
requirement of Section 1 with respect to
qualified Filipinos abroad. The same
Commission has in effect declared that

qualified Filipinos who are not in the
Philippines may be allowed to vote even
though they do not satisfy the residency
requirement in Section 1, Article V of
the Constitution.
 Section 18.5 of R.A. No. 9189, with
respect only to the votes of the President
and Vice-President, and not to the votes
of the Senators and party-list
representatives, is violative of Art. VII,
Sec. 4 of the Constitution.
 Section 4 of R.A. No. 9189 provides that
the overseas absentee voter may vote for
president, vice-president, senators, and
party-list representatives.
 Section 18.5 of the same Act
provides:Sec. 18.On-Site Counting and
Canvassing.—18.5 The canvass of votes
shall not cause the delay of the
proclamation of a winning candidate if
the outcome of the election will not be
affected by the results thereof.
Notwithstanding the foregoing, the
Commission is empowered to order the
proclamation of winning candidates
despite the fact that the scheduled
election has not taken place in a
particular country or countries, if the
holding of elections therein has been
rendered impossible by events, factors
and circumstances peculiar to such
country or countries, in which events,
factors and circumstances are beyond the
control or influence of the Commission.
 Petitioner claims that the provision of
Section 18.5 of R.A. No. 9189
empowering the COMELEC to order the
proclamation of winning candidates for
President and Vice-President is
unconstitutional and violative of the
following provisions of Section 4 of
Article VII of the Constitution:Sec.
4.The returns of every election for
President and Vice-President, duly
certified by the board of canvassers of
each province or city, shall be
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transmitted to the Congress, directed to
the President of the Senate. Upon receipt
of the certificates of canvass, the
President of the Senate shall, not later
than thirty days after the day of the
election, open all the certificates in the
presence of the Senate and the House of
Representatives in joint public session,
and the Congress, upon determination of
the authenticity and due execution
thereof in the manner provided by law,
canvass the votes.
 The person having the highest number of
votes shall be proclaimed elected, but in
case two or more shall have an equal and
highest number of votes, one of them
shall forthwith be chosen by the vote of
a majority of all the Members of both
Houses of the Congress, voting
separately.
 The Congress shall promulgate its rules
for the canvassing of the certificates.
 Congress could not have allowed the
COMELEC to usurp a power that
constitutionally belongs to it or, as aptly
stated by petitioner, to encroach “on the
power of Congress to canvass the votes
for President and Vice-President and the
power to proclaim the winners for the
said positions.” Section 25 of R.A. No.
9189, with respect only to the second
sentence in its second paragraph
allowing Congress to exercise the power
to review, revise, amend, and approve
the IRR that the COMELEC shall
promulgate, is violative of Art. IX-A,
Sec. 1 of the Constitution. Section 25 of
R.A. No. 9189 created the Joint
Congressional Oversight Committee
(JCOC), as follows: Sec. 25. Joint
Congressional Oversight Committee.—a
Joint Congressional Oversight
Committee is hereby created, composed
of the Chairman of the Senate
Committee on Constitutional
Amendments, Revision of Codes and

Laws, and seven (7) other Senators
designated by the Senate President, and
the Chairman of the House Committee
on Suffrage and Electoral Reforms, and
seven (7) other Members of the House of
Representatives designated by the
Speaker of the House of
Representatives: Provided, that of the
seven (7) members to be designated by
each House of Congress, four (4) should
come from the majority and the
remaining three (3) from the minority.
 The Joint Congressional Oversight
Committee shall have the power to
monitor and evaluate the implementation
of this Act. It shall review, revise, amend
and approve the Implementing Rules and
Regulations promulgated by the
Commission. All the parties, petitioner
and respondents alike, are unanimous in
claiming that Section 25 of R.A. No.
9189 is unconstitutional
 The ambit of legislative power under
Article VI of the Constitution is
circumscribed by other constitutional
provisions, one of which is the
aforementioned provision on the
independence of constitutional
commissions. The Court has held that
“whatever may be the nature of the
functions of the Commission on
Elections, the fact is that the framers of
the Constitution wanted it to be
independent from the other departments
of the Government. The Court has no
general powers of supervision over
COMELEC which is an independent
body “except those specifically granted
by the Constitution,” that is, to review its
decisions, orders and rulings. In the
same vein, it is not correct to hold that
because of its recognized extensive
legislative power to enact election laws,
Congress may intrude into the
independence of the COMELEC by
exercising supervisory powers over its
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rule-making authority. In line with this,
this Court holds that Section 25 of R.A.
9189 is unconstitutional and must
therefore be stricken off from the said
law.
7. NICOLAS-LEWIS V. COMMISSION ON
ELECTIONS
 There is no provision in the dual
citizenship law - R.A. 9225 - requiring
"duals" to actually establish residence
and physically stay in the Philippines
first before they can exercise their right
to vote. On the contrary, R.A. 9225, in
implicit acknowledgment that duals are
most likely non-residents, grants under
its Section 5(1) the same right of
suffrage as that granted an absentee
voter under R.A. 9189. It cannot be
overemphasized that R.A. 9189 aims, in
essence, to enfranchise as much as
possible all overseas Filipinos who, save
for the residency requirements exacted
of an ordinary voter under ordinary
conditions, are qualified to vote.
 Constitutional Commission that [it]
intended to enfranchise as much as
possible all Filipino citizens abroad who
have not abandoned their domicile of
origin. The Commission even intended
to extend to young Filipinos who reach
voting age abroad whose parents
domicile of origin is in the Philippines,
and consider them qualified as voters for
the first time. It is in pursuance of that
intention that the Commission provided
for Section 2 [Article V] immediately
after the residency requirement of
Section 1. By the doctrine of necessary
implication in statutory construction, ,
the strategic location of Section 2
indicates that the Constitutional
Commission provided for an exception
to the actual residency requirement of

Section 1 with respect to qualified
Filipinos abroad. The same Commission
has in effect declared that qualified
Filipinos who are not in the Philippines
may be allowed to vote even though they
do not satisfy the residency requirement
in Section 1, Article V of the
Constitution.
 COMELEC itself admits that the
Citizenship Retention and
Re-Acquisition Act expanded the
coverage of overseas absentee voting.
According to the poll body with the
passage of RA 9225 the scope of
overseas absentee voting has been
consequently expanded so as to include
Filipinos who are also citizens of other
countries, subject, however, to the strict
prerequisites indicated in the pertinent
provisions of RA 9225.
 R.A. No. 9225 allows the retention and
8. LOPEZ V. COMMISSION ON ELECTIONS
 While respondent was able to regain his
Filipino Citizenship by virtue of the
Dual Citizenship Law when he took his
oath of allegiance before the Vice
Consul of the Philippine Consulate
Generals Office in Los Angeles,
California, the same is not enough to
allow him to run for a public office. The
above-quoted provision of law mandates
that a candidate with dual citizenship
must make a personal and sworn
renunciation of any and all foreign
citizenship before any public officer
authorized to administer an oath. There
is no evidence presented that will show
that respondent complied with the
provision of R.A. No. 9225. Absent such
proof we cannot allow respondent to run
for Barangay Chairman of Barangay
Bagacay. For the renunciation to be
valid, it must be contained in an affidavit
duly executed before an officer of law
who is authorized to administer an oath.
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The affiant must state in clear and
unequivocal terms that he is renouncing
all foreign citizenship for it to be
effective. In the instant case, respondent
Lopezs failure to renounce his American
citizenship as proven by the absence of
an affidavit that will prove the contrary
leads this Commission to believe that he
failed to comply with the positive
mandate of law. For failure of
respondent to prove that he abandoned
his allegiance to the United States, this
Commission holds him disqualified from
running for an elective position in the
Philippines.
9. SOBEJANA-CONDON V. COMMISSION ON
ELECTIONS
re-acquisition of Filipino citizenship for
natural-born citizens who have lost their
Philippine citizenship by taking an oath
of allegiance to the Republic. The oath is
an abbreviated repatriation process that
restores one’s Filipino citizenship and all
civil and political rights and obligations
concomitant therewith, subject to certain
conditions imposed in Section 5. Section
5(2) of Republic Act No. 9225 compels
natural-born Filipinos, who have been
naturalized as citizens of a foreign
country, but who reacquired or retained
their Philippine citizenship (1) to take
the oath of allegiance under Section 3 of
Republic Act No. 9225, and (2) for those
seeking elective public offices in the
Philippines, to additionally execute a
personal and sworn renunciation of any
and all foreign citizenship before an
authorized public officer prior or
simultaneous to the filing of their
certificates of candidacy, to qualify as
candidates in Philippine elections.

 To qualify as a candidate in Philippine
elections, Filipinos must only have one
citizenship, namely, Philippine
citizenship.
 Foreign laws are not a matter of
judicial notice. Like any other fact,
they must be alleged and proven. To
prove a foreign law, the party invoking it
must present a copy thereof and comply
with Sections 24 and 25 of Rule 132 of
the Revised Rules of Court which
reads:Sec. 24. Proof of official record. –
The record of public documents referred
to in paragraph (a) of Section 19, when
admissible for any purpose, may be
evidenced by an official publication
thereof or by a copy attested by the
officer having the legal custody of the
record, or by his deputy, and
accompanied, if the record is not kept in
the Philippines, with a certificate that
such officer has the custody. If the office
in which the record is kept is in a foreign
country, the certificate may be made by
a secretary of the embassy or legation,
consul general, consul, vice- consul, or
consular agent or by any officer in the
foreign service of the Philippines
stationed in the foreign country in which
the record is kept, and authenticated by
the seal of his office. Sec. 25. What
attestation of copy must state. –
Whenever a copy of a document or
record is attested for the purpose of the
evidence, the attestation must state, in
substance, that the copy is a correct copy
of the original, or a specific part thereof,
as the case may be. The attestation must
be under the official seal of the attesting
officer, if there be any, or if he be the
clerk of a court having a seal, under the
seal of such court.
 The Court has admitted certain
exceptions to the above rules and held
that the existence of a foreign law may
also be established through: (1) a
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testimony under oath of an expert
witness such as an attorney-at-law in the
country where the foreign law operates
wherein he quotes verbatim a section of
the law and states that the same was in
force at the time material to the facts at
hand; and (2) likewise, in several
naturalization cases, it was held by the
Court that evidence of the law of a
foreign country on reciprocity regarding
the acquisition of citizenship, although
not meeting the prescribed rule of
practice, may be allowed and used as
basis for favorable action, if, in the light
of all the circumstances, the Court is
"satisfied of the authenticity of the
written proof offered.
10. MAQUILING V. COMMISSION ON
ELECTIONS
 The use of foreign passport after
renouncing one’s foreign citizenship is a
positive and voluntary act of
representation as to one’s nationality and
citizenship; it does not divest Filipino
citizenship regained by repatriation but it
recants the Oath of Renunciation
required to qualify one to run for an
elective position.
 Such act of using a foreign passport does
not divest Arnado of his Filipino
citizenship, which he acquired by
repatriation. However, by representing
himself as an American citizen, Arnado
voluntarily and effectively reverted to
his earlier status as a dual citizen. Such
reversion was not retroactive; it took
place the instant Arnado represented
himself as an American citizen by using
his US passport. This act of using a

foreign passport after renouncing one’s
foreign citizenship is fatal to Arnado’s
bid for public office, as it effectively
imposed on him a disqualification to run
for an elective local position. In effect,
Arnado was solely and exclusively a
Filipino citizen only for a period of
eleven days, or from 3 April 2009 until
14 April 2009, on which date he first
used his American passport after
renouncing his American citizenship.
 American law does not govern in this
jurisdiction. Instead, Section 40(d) of the
Local Government Code calls for
application in the case before us, given
the fact that at the time Arnado filed his
certificate of candidacy, he was not only
a Filipino citizen but, by his own
declaration, also an American citizen. It
is the application of this law and not of
any foreign law that serves as the basis
for Arnado’s disqualification to run for
any local elective position. This
requirement of renunciation of any and
all foreign citizenship, when read
together with Section 40(d) of the Local
Government Code which disqualifies
those with dual citizenship from running
for any elective local position, indicates
a policy that anyone who seeks to run for
public office must be solely and
exclusively a Filipino citizen. To allow a
former Filipino who reacquires
Philippine citizenship to continue using
a foreign passport – which indicates the
recognition of a foreign state of the
individual as its national – even after the
Filipino has renounced his foreign
citizenship, is to allow a complete
disregard of this policy.
Page 10 of 10
3B 2019-2020
Doctrines for Conflicts
 The renunciation of foreign citizenship
must be complete and unequivocal. The
requirement that the renunciation must
be made through an oath emphasizes the
solemn duty of the one making the oath
of renunciation to remain true to what he
has sworn to. Allowing the subsequent
use of a foreign passport because it is
convenient for the person to do so is
rendering the oath a hollow act. It
devalues the act of taking of an oath,
reducing it to a mere ceremonial
formality.
11. REYES V. COMMISSION ON ELECTIONS
 “xxx for Reyes to reacquire her Filipino
citizenship and become eligible for
public office the law requires that she
must have accomplished the following
acts: (1) take the oath of allegiance to the
Republic of the Philippines before the
Consul-General of the Philippine
Consulate in the USA; and (2) make a
personal and sworn renunciation of her
American citizenship before any public
officer authorized to administer an oath."
In the case at bar, there is no showing
that Reyes complied with the aforesaid
requirements.