case digests on citizenship

8/13/2019 Case Digests on Citizenship

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nder the 2345 Constitution, if the child?s father is a citi$en of the

Philippines, he shall be declared as a citi$en of the Philippines. 'ut

ille"iti!ate children of Filipino !others are required to still elect Filipino

citi$enship upon reachin" the a"e of !a*ority.


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TITLE: MO YA LIM YAO VS.COMMISSIONER OF IMMIGRATION

CITATION: 41 SCRA 292

DATE: OCTOBER 4, 1971

FACTS:

On 8 February 23@2, Lau Auen Aeun" applied for a passport isa to enter the

Philippines as a non#i!!i"rant. 0n the interro"ation !ade in connection %ith

her application for a te!porary isitorBs isa to enter the Philippines, she

stated that she %as a Chinese residin" at (o%loon, on"=on", and that she

desired to ta=e a pleasure trip to the Philippines to isit her "reat "randuncle

Lau Chin" Pin" for a period of one !onth. She %as per!itted to co!e into

the Philippines on 24 March 23@2, and %as per!itted to stay for a period of

one !onth %hich %ould e-pire on 24 )pril 23@2. On the date of her arrial,)sher A, Chen" filed a bond in the a!ount of P2,:::.:: to underta=e, a!on"

others, that said Lau Auen Aeun" %ould actually depart fro! the Philippines

on or before the e-piration of her authori$ed period of stay in this country or

%ithin the period as in his discretion the Co!!issioner of 0!!i"ration or his

authori$ed representatie !i"ht properly allo%.

)fter repeated e-tensions, Lau Auen Aeun" %as allo%ed to stay in the

Philippines up to 24 February 23@;. On ;5 anuary 23@;, she contracted!arria"e %ith Moy Aa Li! Aao alias Edilberto )"uinaldo Li! an alle"ed

Filipino citi$en. 'ecause of the conte!plated action of the Co!!issioner of

0!!i"ration to confiscate her bond and order her arrest and i!!ediate

deportation, after the e-piration of her authori$ed stay, she brou"ht an action

for in*unction %ith preli!inary in*unction. )t the hearin" %hich too= place one

and a half years after her arrial, it %as ad!itted that Lau Auen Aeun" could

not %rite either En"lish or 6a"alo". E-cept for a fe% %ords, she could not

spea= either En"lish or 6a"alo". She could not na!e any Filipino nei"hbor,

%ith a Filipino na!e e-cept one,


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hat is the effect of !arria"e of an alien %o!an to a Filipino Dbefore

the 2389 Constitution/

THE COURTS RULING:

6he Court e-pressly "ae the parties concerned opportunity to proe the fact

that they %ere not sufferin" fro! any of the disqualifications of the la%

%ithout the need of under"oin" any *udicial naturali$ation proceedin". 0t !ay

be stated, therefore, that accordin" to the aboe decisions, the la% in this

country, on the !atter of the ee!" # $%&&'%(e # %) %*'e) +#$%) "# %

F'*'')# '- "%" -e "e&e/ /e!#$e- % F'*'')%, if it can be proen that

at the ti!e of such !arria"e, she does not possess any of the

disqualifications enu!erated in Section 7 of the aturali$ation La%, %ithoutthe need of sub!ittin" to any naturali$ation proceedin"s under said la%.

0t is to be ad!itted that both of the aboe decisions !ade no reference to

qualifications, that is, as to %hether or not they need also to be proed, but,

in any eent, it is a fact that the Secretary of ustice understood the! to

!ean that such qualifications need not be possessed nor proen. 6hen

Secretary of ustice esus 'arrera, %ho later beca!e a distin"uished !e!ber

of this Court, @ so ruled in opinions rendered by hi! subsequent to Ly +io=a, the !ost illustratie of %hich heldG .

)t the outset it is i!portant to note that an alien %o!an !arried to a Filipino

citi$en needs only to sho% that she H!i"ht herself be la%fully naturali$edH in

order to acquire Philippine citi$enship. Co!pliance %ith other conditions of

the statute, such as those relatin" to the qualifications of an applicant for

naturali$ation throu"h *udicial proceedin"s, is not necessary. DSeeG Leonard .

+rant, 5 Fed. 22& ;9 Ops. )tty. +en I>.S.J 5:9& Ops. Sec. of ustice, o. 99@,s. 237:, and o. 222, s. 2354.

6his ie% finds support in the case of Ly +io= a et al. . +alan" et al., +.


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ill an ille"iti!ate child of an alien father and Filipino !other under

the 2345 Constitution need to elect citi$enship to be considered a

natural born/

THE COURTS RULING:

6he rulin" in Mallare %as reiterated and further elaborated in Co s. Electoral

6ribunal of the ouse of


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children and required ille"iti!ate children of Filipino !others to still elect

Filipino citi$enship upon reachin" the a"e of !a*ority.

TITLE: AZNARVS. COMELEC AND OSMEA

CITATION: 1 SCRA 1990

DATE: MA 2, 1990

FACTS:

On oe!ber 23, 2389, priate respondent E!ilio HLitoH Os!eNa filed his

certificate of candidacy %ith the COMELEC for the position of Proincial

+oernor of Cebu Proince in the anuary 28, 2388 local elections.;

On anuary ;;, 2388, petitioner ose '. )$nar in his capacity as its incu!bent

Proincial Chair!an filed %ith the COMELEC a petition for the disqualification

of priate respondent on the "round that he is alle"edly not a Filipino citi$en,

bein" a citi$en of the >nited States of )!erica.4

On anuary ;9, 2388, petitioner filed a For!al Manifestation sub!ittin" aCertificate issued by the then 0!!i"ration and 1eportation Co!!issioner

Miria! 1efensor Santia"o certifyin" that priate respondent is an )!erican

and is a holder of )lien Certificate of


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1urin" the hearin" at the COMELEC Priate respondent, !aintained that he is

a Filipino citi$en, alle"in"G that he is the le"iti!ate child of 1r. E!ilio 1.

Os!eNa, a Filipino and son of the late President Ser"io Os!eNa, Sr.& that he

is a holder of a alid and subsistin" Philippine Passport o. :8552:4 issued

on March ;5, 2389& that he has been continuously residin" in the Philippines

since birth and has not "one out of the country for !ore than si- !onths& and

that he has been a re"istered oter in the Philippines since 23 @5.5

6hereafter, on une 22, 2388, COMELEC DFirst 1iision dis!issed the petition

for disqualification for not hain" been ti!ely filed and for lac= of sufficient

proof that priate respondent is not a Filipino citi$en. ence, the petition for

Certiorari.

ISSUES:

hether or not respondent Os!ena is no lon"er a Filipino

citi$en by acquirin" dual#citi$enship/

hat is the status of one %ho is holder of alien certificate of

re"istration %hile at the sa!e ti!e hain" a alid Philippine

passport/

0s he considered a Filipino/

THE COURTS RULING:

Supre!e Court d is!issed peti tion for certiorar i upholdin"

COMELEC?s decision. 6he petitioner failed to present direct proof

that priate respondent had lost his Filipino citi$enship by any of

the !odes proided for under C.). o. @4. these areG D2 by

naturali$ation in a forei"n country& D; by e-press renunciation of citi$enship&

and D4 by subscribin" to an oath of alle"iance to support the Constitution

or la%s of a forei"n country. Fro! the eidence, it is clear that

priate respondent Os!eNa did not lose his Philippine citi$enship by

any of the three !entioned hereinaboe or by any other !ode of

losin" Philippine citi$enship. 0n the instant case, priate respondent

ehe!ently denies hain" ta=en the oath of alle"iance of the >nited

States. e is a holder of a alid and subsistin" Philippine passport and has


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continuously participated in the electoral process in this country since

23@4 up to the present, both as a oter and as a candidate. 6hus,

priate respondent re!ains a Filipino and the loss of his Philippine

citi$enship cannot be presu!ed. Considerin" the fact that ad!ittedly

Os!eNa %as both a Filipino and an )!erican, the !ere fact that he

has a Certificate statin" he is an )!erican does not !ean that he is

not still a Filipino. 0n the case of Os!eNa, the Certification that he is

an )!erican does not !ean that he is not still a Filipino, possessed

as he is, of both nationalities or citi$enships. 0ndeed, there is no

e-press renunciation here of Phil ippine citi$enship& truth to tell,

there is een no i!plied renunciation of said citi$enship. hen %e

consider that the renunciation needed to lose Philippine citi$enship

!ust be He-pressH, it stands to reason that there can be no such

loss of Philippine Bciti$enship %hen there is no renunciation either

HBe-pressH or Hi!pliedH

TITLE: BENGZON VS.CRUZ

CITATION: G.R. NO. 1420

DATE: MA 7, 2001

FACTS:

Cru$ %as born in 6arlac in 23@: of Filipino parents, but lost his citi$enship

after enlistin" in the >S Marine Corps and later naturali$ed as a >S citi$en. e

reacquired his citi$enship throu"h repatriation and ran for Con"ress. hen he

%on, his opponent clai!ed that he %as no lon"er a natural#born Filipino and

therefore ineli"ible as a !e!ber of Con"ress.


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6he Supre!e Court ruled in faor of Cru$, statin" that repatriation allo%s

one to recoer, or return to, his ori"inal status before he lost his Philippine

citi$enship.

6he 2389 Constitution defines natural#born citi$ens as those citi$ens of the

Philippines %ithout hain" to perfor! any act to acquire or perfect his

Philippine citi$enship.

ISSUE:

hether or not repatriation causes a person, for!erly a natural#born

Filipino, to re"ain his citi$enship in its ori"inal state/

THE COURTS RULING:

aturali$ation is a !ode for both acquisition and reacquisition of Philippine

citi$enship. Co!!on%ealth )ct o. 794or the nited States at any other ti!e& D4 !arria"e of a Filipino %o!an to an

alien& and D7 political and econo!ic necessity. I4J

)side fro! different require!ents, naturali$ation and repatriation also hae

different processes. )s distin"uished fro! the len"thy process of

naturali$ation, repatriation si!ply consists of the ta=in" of an oath of

alle"iance to the


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i!portance %as "ien to those %ho hae lost their citi$enship throu"h the

desertion of the ar!ed forces, serice in the )r!ed Forces of the >nited

States, !arria"e of a Filipino %o!an to a forei"ner, and political or econo!ic

necessity. 1ue to this distinction !ade, it is understandable that these

people hae been "ien the priile"e to re"ain their ori"inal citi$enship

%ithout "oin" throu"h the !ore tedious process of naturali$ation.

o%eer, there is still so!e a!bi"uity, since the Constitution itself states

that natural#born citi$ens are those %ho do not need to perfor! any other act

to perfect or obtain their citi$enship. 6hou"h reacquisition is not !entioned,

it could be said that their citi$enship, if not totally lost, %as burdened by

so!e i!perfection, since they so!eho% "ained alle"iance to another

country. Since they need to perfor! an act to perfect their citi$enship once

a"ain, they should be considered naturali$ed and not natural born citi$ens.

ustice +uttiere$, in his dissent, said that the proision on natural born

citi$enship is precise, clear and definite, and should not be construed in

any other %ay aside fro! %hat its plain !eanin" coneys. e said that it

%as an issue that should be left to Constitutional a!end!ent.

TITLE: FRIVALDOVS.COMELEC


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CITATION: 174 SCRA 24 AND 27 SCRA 727

DATE: 5UNE 23, 199

FACTS:

Petitioner uan +. Frialdo %as proclai!ed "oernor#elect and assu!e officein due ti!e. 6he Lea"ue of Municipalities filed %ith the COMELEC a petition

for annul!ent of Frialdo?s election and procla!ation on the "round that he

%as not a Filipino citi$en, hain" been naturali$ed in the >nited States.

Frialdo ad!itted the alle"ation but pleaded the special and affir!atie

defenses that his naturali$ation %as !erely forced upon hi!self as a !eans

of surial a"ainst the unrelentin" prosecution by the Martial La% 1ictator?s

a"ent abroad.

ISSUES:

hether or not Frialdo %as a citi$en of the Philippines at the ti!e of

his election/

hat is the effect of repatriation/

hen should the repatriation be rec=oned/

THE COURTS RULING:

o. Section 229 of the O!nibus Election Code proides that a qualified oter

!ust be, a!on" other qualifications, a citi$en of the Philippines, this bein" an

indispensable require!ent for suffra"e under )rticle V, Section 2, of the

Constitution. Een if he did lose his naturali$ed )!erican citi$enship, such

forfeiture did not and could not hae the effect of auto!atically restorin" his

citi$enship in the Philippines that he had earlier renounced. Kualifications for

public office are continuin" require!ents and !ust be possessed not only at

the ti!e of appoint!ent or election or assu!ption of office but durin" the

officer?s entire tenure. Frialdo declared not a citi$en of the Philippines and

therefore disqualified fro! serin" as a +oernor of the Proince of Sorso"on.

0n his


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candidacy that he %as a natural#born citi$en should be a sufficient act of

repatriation.

)dditionally, his actie participation in the 2389 con"ressional elections had

diested hi! of )!erican citi$enship under the la%s of the >nited States,

thus restorin" his Philippine citi$enship. e ended by reiteratin" his prayerfor the re*ection of the !oe to disqualify hi! for bein" ti!e#barred under

Section ;54 of the O!nibus Election Code.

6here is yet another reason %hy the pri!e issue of citizenship should be

rec=oned fro! the date of procla!ation, not necessarily the date of election

or date of filin" of the certificate of candidacy. Section ;54 of the O!nibus

Election Code "ies any oter, presu!ably includin" the defeated candidate,

the opportunity to question the EL0+0'0L06A Dor the disloyalty of a candidate.

6his is the only proision of the Code that authori$es a re!edy on ho% to

contest before the COMELEC an incu!bentBs ineli"ibility arisin" fro! failure

to !eet the qualifications enu!erated under Sec. 43 of the Local

+oern!ent Code. Such re!edy of Quo Warranto can be aailed of H%ithin

ten days after procla!ationH of the %innin" candidate. ence, it is only at

such time that the issue of ineli"ibility !ay be ta=en co"ni$ance of by theCo!!ission. )nd since, at the ery !o!ent of LeeBs procla!ation D8G4: p.!.,

une 4:, 2335, uan +. Frialdo %as already and indubitably a citi$en, hain"

ta=en his oath of alle"iance earlier in the afternoon of the sa!e day, then he

should hae been the candidate proclai!ed as he unquestionably "arnered

the hi"hest nu!ber of otes in the i!!ediately precedin" elections and such

oath had already cured his preious H*udicially#declaredH aliena"e. ence, at

such ti!e, he %as no lon"er ineli"ible.


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TITLE: COVS. HRET

CITATION: G.R. NO. 9219192

DATE: 5UL 30, 1991

FACTS:

6he


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born in China in 23:5 but %as brou"ht by On" 6e to Sa!ar in the year 2325,

he filed %ith the court an application for naturali$ation and %as declared a

Filipino citi$en. 0n 2387, the priate respondent !arried a Filipina na!ed

1esiree Li!. For the elections of 2387 and238@, ose On", r. re"istered

hi!self as a oter of Laoan", Sa!ar, and oted there durin" those elections.

>nder the 2394 Constitution, those born of Filipino fathers and those born of

Filipino !others %ith an alien father %ere placed on equal footin". 6hey %ere

both considered as natural born citi$ens. 'esides, priate respondent did

!ore than !erely e-ercise his ri"ht of suffra"e. e has established his life

here in the Philippines. On the issue of residence, it is not required that a

person should hae a house in order to establish his residence and do!icile.

0t is enou"h that he should lie in the !unicipality or in a rented house or in

that of a friend or relatie. 6o require hi! to o%n property in order to be

eli"ible to run for Con"ress %ould be tanta!ount to a property qualification.

6he Constitution only requires that the candidate !eet the a"e, citi$enship,

otin" and residence require!ents.

6hose born before anuary 29, 2394, of Filipino !others, %ho elect Philippine

citi$enship upon reachin" the a"e of !a*ority.

6he Court in this case is faced %ith the duty of interpretin" the aboe#quoted

constitutional proisions. 6he first sentence of Section ; of )rticle 0V states

the basic definition of a natural#born Filipino citi$en. 1oes priate respondentfall %ithin said definition/

6o the respondent tribunal,

Protestee !ay een be declared a natural#born citi$en of the Philippines

under the first sentence of Sec. ; of )rticle 0V of the 2389 Constitution

because he did not hae Hto perfor! any act to acquire or perfect his

Philippine citi$enship.H 0t bears to repeat that on 25 May 2359, %hile still a

!inor of 3 years he already beca!e a Filipino citi$en by declaration of la%.

Since his !other %as a natural#born citi$en at the ti!e of her !arria"e,

protestee had an inchoate ri"ht to Philippine citi$enship at the !o!ent of his

birth and, consequently the declaration by irtue of Sec. 25 of C) 794 that he

%as a Filipino citi$en retroacted to the !o!ent of his birth %ithout his hain"

to perfor! any act to acquire or perfect such Philippine citi$enship.


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Second sentence in )rticle 0V, Section ; of the 2389 Constitution. 0t e-pands,

in a !anner of spea=in", in relation to Section 2, para"raph D4 of the sa!e

)rticle 0V, the status of a natural#born Filipino citi$en to those %ho elect

Philippine citi$enship upon reachin" the a"e of !a*ority. 6he ri"ht or priile"e

of election is aailable, ho%eer, only to those born to Filipino !others under

the 2345 Constitution, and before the 2394 Constitution too= effect on 29

anuary 2394.

TITLE: TABASAVS.COURT OF APPEALSCITATION: G.R. NO. 12793

DATE: AUGUST 29, 2006

FACTS:

6he facts as culled by the C) fro! the records sho% that petitioner oeanie

)rellano 6abasa %as a natural#born citi$en of the Philippines. 0n 23@8, I4J%hen

petitioner %as seen years old,I7Jhis father, nited States. 'y deriatie naturali$ationDciti$enship deried fro! that of another as fro! a person %ho holds

citi$enship by irtue of naturali$ationI@J, petitioner also acquired )!erican

citi$enship.

Petitioner arried in the Philippines on )u"ust 4, 2335, and %as ad!itted as

a bali=bayan for one year. 6hereafter, petitioner %as arrested and detained

by a"ent ilson Soluren of the '01 on May ;4, 233@, pursuant to '01 Mission
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Order o. L0V#3@#9; in 'aybay, Malay, )=lan& subsequently, he %as brou"ht

to the '01 1etention Center in Manila.I9J

Petitioner %as inesti"ated by Special Prosecutor )tty. Edy 1. 1onato at the

La% and 0nesti"ation 1iision of the '01 on May ;8, 233@& and on the sa!e

day, 6abasa %as accused of iolatin" Section 8, Chapter 4, 6itle 2, 'oo= 4 of

the 2389 )d!inistratie Code, in a char"e sheet %hich alle"edG

2. 6hat on 4 )u"ust 2335, respondent Dpetitioner

herein I6abasaJ arried in the Philippines and %as

ad!itted as a bali=bayan&

;. 6hat in a letter dated 2@ )pril 233@, onorable(ein erbert, Consul +eneral of ItheJ >.S. E!bassy,

infor!ed the 'ureau that respondent?s Passport o.

:54857283 issued on une 2:, 2337 in San Francisco,

California, >.S.)., had been reo=ed by the >.S.

1epart!ent of State&

4. ence, respondent Ipetitioner 6abasa is no%

an undocu!ented and undesirable alien and !ay besu!!arily deported pursuant to La% and 0ntelli"ence

0nstructions o. 54 issued by then Co!!issioner Miria!

1efensor Santia"o to effect his deportation DE-hibit 4.

Petitioner filed before the C) a Petition for Habeas Corpus%ith Preli!inary

0n*unction andor 6e!porary


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detention, and restrained the 'ureau fro! su!!arily deportin" hi!. On une

4, 233@, the '01 presented 6abasa before the C)& and on une @, 233@, the

C) "ranted both parties ten D2: days %ithin %hich to file their !e!oranda,

after %hich the case %ould be considered sub!itted for decision. Mean%hile,

the Co!!issioner of 0!!i"ration "ranted the petitioner?s te!porary release

on bail on a PhP ;:,:::.:: cash bond.

o%eer, on une 24, 233@, petitioner filed a Supple!ental Petition alle"in"

that he had acquired Filipino citi$enship by repatriation in accordance %ith


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D4 Person conicted of cri!es inolin" !oral turpitude& or

D7 Person sufferin" fro! !ental alienation or incurable conta"ious

diseases.

Petitioner 6abasa qualified as a natural#born Filipino %ho had not lost his

Philippine citi$enship by reason of political or econo!ic necessity under


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CITATION: 307 SCRA 630. G.R. NO. 1303DATE: MA 26, 1999

FACTS:

Petitioner Ernesto Mercado and Priate respondent Eduardo Man$ano are

candidates for the position of Vice#Mayor of Ma=ati City in the May, 2338

elections. Priate respondent %as the %inner of the said election but the

procla!ation %as suspended due to the petition of Ernesto Ma!aril

re"ardin" the citi$enship of priate respondent. Ma!aril alle"ed that the

priate respondent is not a citi$en of the Philippines but of the >nited States.

COMELEC "ranted the petition and disqualified the priate respondent for

bein" a dual citi$en, pursuant to the Local +oern!ent code that proides

that persons %ho possess dual citi$enship are disqualified fro! runnin" any

public position. Priate respondent filed a !otion for reconsideration %hich

re!ained pendin" until after election. Petitioner sou"ht to interene in the

case for disqualification. COMELEC reersed the decision and declared

priate respondent qualified to run for the position. Pursuant to the rulin" of

the COMELEC, the board of canassers proclai!ed priate respondent as ice

!ayor. 6his petition sou"ht the reersal of the resolution of the COMELEC

and to declare the priate respondent disqualified to hold the office of the

ice !ayor of Ma=ati.

ISSUES:

hether or ot priate respondent is qualified to hold office as Vice#

Mayor/

hat is the effect of one?s certificate of candidacy on his alienciti$enship/

THE COURTS RULING:

1ual citi$enship is different fro! dual alle"iance. 6he for!er arises %hen, as

a result of the concurrent application of the different la%s of t%o or !ore

states, a person is si!ultaneously considered a national by the said states.

For instance, such a situation !ay arise %hen a person %hose parents areciti$ens of a state %hich adheres to the principle of *us san"uinis is born in a

state %hich follo%s the doctrine of *us soli. Priate respondent is considered

as a dual citi$en because he is born of Filipino parents but %as born in San

Francisco, >S). Such a person, ipso facto and %ithout any oluntary act on

his part, is concurrently considered a citi$en of both states. Considerin" the

citi$enship clause D)rt. 0V of our Constitution, it is possible for the follo%in"

classes of citi$ens of the Philippines to posses dual citi$enshipG


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D2 6hose born of Filipino fathers andor !others in forei"n countries %hich

follo% the principle of *us soli&

D; 6hose born in the Philippines of Filipino !others and alien fathers if by the

la%s of their fathers? country such children are citi$ens of that country&

D4 6hose %ho !arry aliens if by the la%s of the latter?s country the for!er

are considered citi$ens, unless by their act or o!ission they are dee!ed to

hae renounced Philippine citi$enship.

1ual alle"iance, on the other hand, refers to the situation in %hich a person

si!ultaneously o%es, by so!e positie act, loyalty to t%o or !ore states.

hile dual citi$enship is inoluntary, dual alle"iance is the result of an

indiidual?s olition.

'y filin" a certificate of candidacy %hen he ran for his present post, priate

respondent elected Philippine citi$enship and in effect renounced his

)!erican citi$enship. 6he filin" of such certificate of candidacy sufficed to

renounce his )!erican citi$enship, effectiely re!oin" any disqualification

he !i"ht hae as a dual citi$en.

'y declarin" in his certificate of candidacy that he is a Filipino citi$en& that he

is not a per!anent resident or i!!i"rant of another country& that he %ill

defend and support the Constitution of the Philippines and bear true faith and

alle"iance thereto and that he does so %ithout !ental reseration, priate

respondent has, as far as the la%s of this country are concerned, effectiely

repudiated his )!erican citi$enship and anythin" %hich he !ay hae said

before as a dual citi$en. On the other hand, priate respondent?s oath of

alle"iance to the Philippine, %hen considered %ith the fact that he has spent

his youth and adulthood, receied his education, practiced his profession asan artist, and ta=en part in past elections in this country, leaes no doubt of

his election of Philippine citi$enship.


22/23


23/23

!a=e a personal and s%orn renunciation of any and all forei"n citi$enship

before any public officer authori$ed to ad!inister an oath.

e aers that he e-ecuted an act of renunciation of his >S citi$enship,

separate fro! the Oath of )lle"iance to the

case digests on citizenship

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