Case Digest

AASJS vs Datumanong
AASJS vs Datumanong

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."

ISSUE: By recognizing & allowing dual allegiance, is RA 9225 unconstitutional?

HELD: No. 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.