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philippine citizenship
Civil Law•Conflicts of Law•Law School Notes

Rommel Arnado vs. COMELEC

January 30, 2023 by Vala No Comments

G.R. No. 210164. August 18, 2015.

FACTS:

Petitioner Arnado is a natural-born Filipino citizen who lost his Philippine citizenship after he was naturalized as a citizen of the United States of America (USA). Subsequently, and in preparation for his plans to run for public office in the Philippines, Arnado applied for repatriation under Republic Act No. 9225. He took an Oath of Allegiance to the Republic of the Philippines and on April 3, 2009, he executed an Affidavit of Renunciation of his foreign citizenship. On November 30, 2009, Arnado filed his Certificate of Candidacy (CoC) for the mayoralty post of Kauswagan, Lanao del Norte. 

Balua, another mayoralty candidate, however, filed a petition to disqualify Arnado and/or to cancel his CoC on the ground, among others, that Arnado remained a US citizen because he continued to use his US passport for entry to and exit from the Philippines after executing aforesaid Affidavit of Renunciation.

Arnado won the election, however, COMELEC declared that Arnado’s act of consistently using his US passport effectively negated his Affidavit of Renunciation.

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Civil Law•Conflicts of Law•Constitutional Law•Law School Notes•Political Law

Antonio Bengzon III vs. House of Representative Electoral Tribunal.

by Vala No Comments

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.

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