G.R. No. 135083, May 26, 1996.

FACTS:

Mercado and Manzano were candidates for vice mayor of the City of Makati. Manzano won the election but his proclamation was suspended in view of a pending petition for disqualification filed by a certain Ernesto Mamaril who alleged he was not a citizen of the Philippines but of the United States.

• The disqualification of private respondent Manzano is being sought under §40 of the Local Government Code of 1991 which provides that “those who have dual citizenship are disqualified from running for any elective local position”. 
• He argues that merely taking part in Philippine elections is not sufficient evidence of renunciation of U.S. citizenship

Manzano was born in San Francisco, California, U.S.A. He acquired US citizenship by operation of the United States Constitution and laws under the principle of jussoli. He was also a natural born Filipino citizen by operation of the 1935 Philippine Constitution, as his father and mother were Filipinos at the time of his birth. He is registered as an American citizen in the Bureau of Immigration and Deportation and holds an American passport which he used in his last travel to the United States on April 22, 1997.

G.R. No. 142840, May 7, 2001

FACTS:

Respondent Cruz was a natural-born citizen of the Philippines. However he enlisted in the United States Marine Corps and, without the consent of the Republic of the Philippines, took an oath of allegiance to the United States.

After almost 9 years, Cruz reacquired his Philippine citizenship through repatriation under Republic Act No. 2630. He ran and was elected as the Representative of the Second District of Pangasinan.

Bengzon claimed that respondent Cruz was not qualified to become a member of the House of Representatives since he is not a natural-born citizen when he swore allegiance to the United States in 1995, and had to reacquire the same by repatriation.

Respondent on the other hand contends that he reacquired his status as a natural-born citizen when he was repatriated since the phrase “from birth” in Article IV, Section 2 refers to the innate, inherent and inborn characteristic of being a natural-born citizen.

G.R. No. 228236, January 27, 2021.

FACTS:

Panga-Vega, then Secretary of the House of Representatives Electoral Tribunal (HRET), requested authority to avail of the 15 days of special leave benefit under Republic Act (RA) No. 9710, otherwise known as the Magna Carta of Women to undergo hysterectomy.  The HRET approved Panga-Vega’s request for special leave for a period not exceeding two months starting February 7, 2011.  After a month of availing of the special leave, Panga­ Vega informed the HRET Chairperson that she was reassuring her duties and functions. She also presented a medical certificate that she was already “fit to work”.  The HRET directed Panga-Vega to consume her 2-month special leave given her need for prolonged rest following her hysterectomy, and in view of a pending investigation on her alleged alteration or tampering one minute of the meeting that could subject her to more stress. She sought reconsideration of this HRET Resolution but was denied pointing out the confusion and doubts regarding her true medical condition as caused by her medical certificates. 

The CSC ruled that she only needed to present a medical certificate attesting her physical fitness to return to work and need not exhaust the full leave she applied for under RA No. 9710. It was further held that applying the rules on maternity leave, she is entitled to both the commuted money value of the unexpired portion of the special leave and her salary for actual services rendered effective the day she reported back for work. 

G.R. No. 216492, January 20, 2021.

FACTS

Garin (Garin), a resident of Pasig City, wanted to build a house in Katarungan Village in Muntinlupa City. Per Section 10 of Muntinlupa City Ordinance No. 02-047, one of the prerequisites to secure a building permit is a clearance from the homeowners’ association. Garin requested clearance from Katarungan Village Homeowners Association (Katarungan), but clarified that “he is not a member of the association.” However, Katarungan refused to give the required clearance until he paid an assessment fee and signed up for membership in their association. 

Garin filed a Petition for Mandamus to compel the City of Muntinlupa to accept his application for processing, even without the required clearance. He also prayed that Section 10 of Muntinlupa City Ordinance No. 02-047 be declared unconstitutional “insofar as it relates to the tasking of the homeowners association for the issuance of clearance.

The RTC denied petitioner’s application for preliminary injunction and suspended the case pending petitioner’s exhaustion of administrative remedies.