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