Mercado vs.

Manzano
FACTS:
Petitioner and respondent were
opposing candidates for vicemayor. Respondent was born in the
United States of Filipino parents.
Petitioner argued that respondent
was not eligible, because he used
an American passport in his last
travel to the United States before
he files his certificate of candidacy;
and he registered as an American
citizen
in
the
Bureau
of
Immigration and Deportation.
HELD:
There is no merit in the contention.
The acts attributed to respondent
can be considered simply as the
assertion
of
his
American
nationality before the termination
of his American citizenship.

Valles vs. COMELEC

FACTS:
Respondent was born in Australia
of a Filipino father and an
Australian mother. Australia follows
jus soli. Respondent ran for
governor. Petitioner, her opponent,
filed a petition to disqualify her on
the ground of dual citizenship.
HELD:
Dual
citizenship
as
a
disqualification
must
refer
to
citizens with dual allegiance. The
fact that respondent had dual
citizenship did not automatically

disqualify her from running for a

public office. The filing of a
certificate of candidacy sufficed to
renounce
foreign
citizenship,
because in the certificate of
candidacy one declares that he is a
Filipino citizen and that he will
support
and
defend
the
Constitution of the Philippines.
Such declaration operates as an
effective renunciation of foreign
citizenship.

Yu vs. Defensor-Santiago
FACTS:
A Portuguese national, whose
application for naturalization as a
Filipino citizen was granted and
who, after taking his oath as a
naturalized Filipino, applied for
renewal of his Portuguese passport
and
declared
in
commercial
documents executed abroad that
he was a Potuguese national.
HELD:

Bengson vs. House of

Representatives Electoral Tribunal
FACTS:
Respondent, a natural born Filipino
citizen, enlisted in the United
States Marine Corps. He took an
oath of allegiance to the United
States. Later on, he became
naturalized as an American citizen.
He repatriated under Republic Act
2630 and ran against respondent

as member of the House of

Representatives. Respondent won.
Petitioner filed a quo warranto case
against him on the ground that he
was not a natural born Filipino
citizen.
HELD:
The contention is without merit.
Repatriation results in the recovery
of the original nationality. If a
Filipino 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.

Poe-Llamanzares vs. COMELEC

Ugdoracion Jr. vs. COMELEC

Tecson vs. COMELEC

FACTS:
Respondent files his certificate of
candidacy for President. He stated
in it that he was a natural-born
citizen of the Philippines. Petitioner
filed in the Commission on
Elections a petition to disqualify
respondent, who was born on
August 20, 1939, on the ground
that
he
made
a
material
misrepresentation in his certificate
of candidacy by claiming to be a

natural-born
citizen
of
the
Philippines. Petitioner argued that
even if the father of petitioner was
a Filipino, he was not a natural-born
citizen of the Philippines, because
his mother was an American
citizen, he was an illegitimate child
and an illegitimate child follows the
citizenship of the mother.
HELD:
Section 1, Article III of the 1935
Constitution
provides,
those
whose fathers are citizens of the
Philippines are citizens of the
Philippines. It would violate the
equal protection clause of the
Constitution to make a distinction
between the citizenship of a
legitimate
child
and
of
an
illegitimate child and a distinction
between the citizenship of an
illegitimate child of a Filipino father
and the illegitimate child of a
Filipino mother. Legitimacy or
illegitimacy has no relevance to
elective public service. There can
be no possible State interest for
disqualifying an illegitimate from
becoming a public officer. In
providing that those whose fathers
are citizens of the Philippines are
citizens of the Philippines, the 1935
Constitution
provides
neither
conditions nor distinctions. There is
no
justification
to
prescribe
conditions or distinctions where
there clearly are none provided.