Mercado v.

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

Facts:
Petitioners filed for respondents disqualification for election alleging that respondent is a dual citizen, and
under the Local Government Code, dual citizens cannot run for public office.

Respondent is a son of both Filipinos but was born in the U.S which follows the principle of jus soli, hence,
considered an American citizen as well.
COMELEC allowed Manzano to run because he was considered natural-born because of the vrtue that he is
a son of both Filipino citizens but petitioners assail this.

Issue: Is respondent Manzano a dual citizen and cannot run for public office?
Ruling: The Court first defined dual citizenship and compared it to dual allegiance.

Dual citizenship arises when a person whose parents are citizens of a state that follows jus saguinis and was
born in a state that follows jus soli, hence, resulting to a concurrent application of different two laws or
more.
On the other hand, dual allegiance is a situation whre a person simultaneously owes loyalty to two or more
states.

In this case, Respondent, though dual citizen, his act of filing a certificate of candidacy tantamount to his
election of Phil. citizenship meaning he forswears allegiance to the other country and thereby terminating
their status as dual.
The Court stressed that participating in the election is an express renunciation of American citizenship.