Yu vs. Defensor-Santiago, G.R. No. L-83882, Jan.

24, 1989
FACTS: Petitioner is a Portuguese national who acquired Philippine citizenship by
naturalization. However, despite his naturalization, he still applied for and was
issued a Portuguese passport and declared his nationality as Portuguese in
commercial documents he signed.
ISSUE: Whether petitioners acts constitute renunciation of his Philippine citizenship
HELD: Express renunciation means a renunciation that is made known distinctly
and explicitly and not left to inference or implication. Petitioner, with full knowledge,
and legal capacity, after having renounced his Portuguese citizenship upon
naturalization as a Philippine citizen resumed or reacquired his prior status as a
Portuguese citizen, applied for a renewal of his Portuguese passport. To the mind of
the court the foregoing acts considered together constitute an express renunciation
of petitioners Philippine citizenship acquired through naturalization.