Sections 4 and 5 Citizenship

7/23/2019 Sections 4 and 5 Citizenship

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SECTION 4. Citizens of the Philippines who marry aliens shall retain their citizenship, unless

by their act or omission they are deemed, under the law, to have renounced it.

LABO V. COMELEC

The petitioner's contention that his marriage to an Australian national in 1976 did notautomatically divest him of Philippine citizenship is irrelevant. There is no claim or finding

that he automatically ceased to be a Filipino because of that marriage. He became a

citizen of Australia because he was naturalized as such through a formal and positive

process, simplified in his case because he was married to an Australian citizen. As a

condition for such naturalization, he formally took the Oath of Allegiance and/or made

the Affirmation of Allegiance, both quoted above. Renouncing all other allegiance, he

swore "to be faithful and bear true allegiance to Her Majesty Elizabeth the Second,

Queen of Australia ..." and to fulfill his duties "as an Australian citizen."

Even if it be assumed that, as the petitioner asserts, his naturalization in Australia was

annulled after it was found that his marriage to the Australian citizen was bigamous, that

circumstance alone did not automatically restore his Philippine citizenship. His divestiture

of Australian citizenship does not concern us here. That is a matter between him and his

adopted country. What we must consider is the fact that he voluntarily and freely

rejected Philippine citizenship and willingly and knowingly embraced the citizenship of a

foreign country. The possibility that he may have been subsequently rejected by

Australia, as he claims, does not mean that he has been automatically reinstated as a

citizen of the Philippines.

DJUMANTAN V. DOMINGO

The fact of marriage by an alien to a citizen does not withdraw her from the operation of

the immigration laws governing the admission and exclusion of aliens. Marriage of an

alien woman to a Filipino husband does not ipso factomake her a Filipino citizen and

does not excuse her from her failure to depart from the country upon the expiration ofher extended stay here as an alien.

MERCADO V. MANZANO

Petitioner Mercado and private respondent Manzano were candidates for vice mayor of

the City of Makati in the May 11, 1998 elections. The proclamation of private respondent

was suspended in view of a pending petition for disqualification filed by a certain Ernesto

Mamaril who alleged that private respondent was not a citizen of the Philippines but of

the United States. The Second Division of the COMELEC granted the petition of Mamaril

and ordered the cancellation of the certificate of candidacy of private respondent on

the ground that he is a dual citizen and under Sec. 40 of the Local Government Code,

persons with dual citizenship are disqualified from running for any elective position.

ON DUAL ALLEGIANCE: The disqualification of private respondent Manzano is being

sought under 40 of the Local Government Code of 1991 (R.A. No. 7160), which declares

as disqualified from running for any elective local position: . . . (d) Those with dual

citizenship. This provision is incorporated in the Charter of the City of Makati.

Invoking the maxim dura lex sed lex, petitioner, as well as the Solicitor General, who sides

with him in this case, contends that through 40(d) of the Local Government Code,


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Congress has command[ed] in explicit terms the ineligibility of persons possessing dual

allegiance to hold local elective office.

To begin with, dual citizenship is different from dual allegiance. The former arises when, as

a result of the concurrent application of the different laws of two or more states, a person

is simultaneously considered a national by the said states. For instance, such a situation

may arise when a person whose parents are citizens of a state which adheres to theprinciple ofjus sanguinisis born in a state which follows the doctrine ofjus soli. Such a

person, ipso factoand without any voluntary act on his part, is concurrently considered a

citizen of both states.

Considering the citizenship clause (Art. IV) of our Constitution, it is possible for the

following classes of citizens of the Philippines to possess dual citizenship:

(1) Those born of Filipino fathers and/or mothers in foreign countries which follow

the principle of jus soli;

(2) Those born in the Philippines of Filipino mothers and alien fathers if by the laws

of their fathers country such children are citizens of that country;

(3) Those who marry aliens if by the laws of the latters country the former are

considered citizens, unless by their act or omission they are deemed to have

renounced Philippine citizenship.

There may be other situations in which a citizen of the Philippines may, without

performing any act, be also a citizen of another state; but the above cases are clearly

possible given the constitutional provisions on citizenship.

Dual allegiance, on the other hand, refers to the situation in which a person

simultaneously owes, by some positive act, loyalty to two or more states. While dual

citizenship is involuntary, dual allegiance is the result of an individuals volition.

Clearly, in including 5 in Article IV on citizenship, the concern of the Constitutional

Commission was not with dual citizens per sebut with naturalized citizens who maintain

their allegiance to their countries of origin even after their naturalization. Hence, thephrase dual citizenship in R.A. No. 7160, 40(d) and in R.A. No. 7854, 20 must be

understood as referring to dual allegiance. Consequently, persons with mere dual

citizenship do not fall under this disqualification. Unlike those with dual allegiance, who

must, therefore, be subject to strict process with respect to the termination of their status,

for candidates with dual citizenship, it should suffice if, upon the filing of their certificates

of candidacy, they elect Philippine citizenship to terminate their status as persons with

dual citizenship considering that their condition is the unavoidable consequence of

conflicting laws of different states. As Joaquin G. Bernas, one of the most perceptive

members of the Constitutional Commission, pointed out: [D]ual citizenship is just a reality

imposed on us because we have no control of the laws on citizenship of other countries.

We recognize a child of a Filipino mother. But whether or not she is considered a citizen

of another country is something completely beyond our control.

By declaring in his certificate of candidacy that he is a Filipino citizen; that he is not a

permanent resident or immigrant of another country; that he will defend and support the

Constitution of the Philippines and bear true faith and allegiance thereto and that he

does so without mental reservation, private respondent has, as far as the laws of this

country are concerned, effectively repudiated his American citizenship and anything

which he may have said before as a dual citizen.


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On the other hand, private respondents oath of allegiance to the Philippines, when

considered with the fact that he has spent his youth and adulthood, received his

education, practiced his profession as an artist, and taken part in past elections in this

country, leaves no doubt of his election of Philippine citizenship.

His declarations will be taken upon the faith that he will fulfill his undertaking made under

oath. Should he betray that trust, there are enough sanctions for declaring the loss of hisPhilippine citizenship through expatriation in appropriate proceedings.

VALLES V. COMELEC

Rosalind Ybasco Lopez was born on May 16, 1934 in Napier Terrace, Broome, Western

Australia, to the spouses, Telesforo Ybasco, a Filipino citizen and native of Daet,

Camarines Norte, and Theresa Marquez, an Australian. In 1949, at the age of fifteen, she

left Australia and came to settle in the Philippines.

On June 27, 1952, she was married to Leopoldo Lopez, a Filipino citizen, at the Malate

Catholic Church in Manila. Since then, she has continuously participated in the electoral

process not only as a voter but as a candidate, as well. She served as Provincial Board

Member of the Sangguniang Panlalawigan of Davao Oriental. In 1992, she ran for and

was elected governor of Davao Oriental. Her election was contested by her opponent,

Gil Taojo, Jr., in a petition for quo warranto, docketed as EPC No. 92-54, alleging as

ground therefor her alleged Australian citizenship.

In the aforecited case ofMercado vs. Manzano, the Court clarified dual citizenship as

used in the Local Government Code and reconciled the same with Article IV, Section 5

of the 1987 Constitution on dual allegiance. Recognizing situations in which a Filipino

citizen may, without performing any act, and as an involuntary consequence of the

conflicting laws of different countries, be also a citizen of another state, the Court

explained that dual citizenship as a disqualification must refer to citizens with dual

allegiance. The Court succinctly pronounced:

xxx the phrase dual citizenship in R.A. No. 7160, xxx 40 (d) and in R.A. No. 7854, xxx

20 must be understood as referring to dual allegiance. Consequently, persons

with mere dual citizenship do not fall under this disqualification.

Thus, the fact that the private respondent had dual citizenship did not automatically

disqualify her from running for a public office. Furthermore, it was ruled that for

candidates with dual citizenship, it is enough that they elect Philippine citizenship upon

the filing of their certificate of candidacy, to terminate their status as persons with dual

citizenship. The filing of a certificate of candidacy sufficed to renounce foreign

citizenship, effectively removing any disqualification as a dual citizen. This is so because

in the certificate of candidacy, one declares that he/she is a Filipino citizen and that

he/she will support and defend the Constitution of the Philippines and will maintain truefaith and allegiance thereto. Such declaration, which is under oath, operates as an

effective renunciation of foreign citizenship. Therefore, when the herein private

respondent filed her certificate of candidacy in 1992, such fact alone terminated her

Australian citizenship.

Then, too, it is significant to note that on January 15 1992, private respondent executed a

Declaration of Renunciation of Australian Citizenship, duly registered in the Department

of Immigration and Ethnic Affairs of Australia on May 12, 1992. And, as a result, on


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February 11, 1992, the Australian passport of private respondent was cancelled, as

certified to by Second Secretary Richard F. Munro of the Embassy of Australia in Manila.

As aptly appreciated by the COMELEC, the aforesaid acts were enough to settle the

issue of the alleged dual citizenship of Rosalind Ybasco Lopez. Since her renunciation

was effective, petitioners claim that private respondent must go through the whole

process of repatriation holds no water.

Petitioner maintains further that when citizenship is raised as an issue in judicial or

administrative proceedings, the resolution or decision thereon is generally not considered

res judicatain any subsequent proceeding challenging the same; citing the case ofMoy

Ya Lim Yao vs. Commissioner of Immigration.

Petitioner is correct insofar as the general rule is concerned, i.e.the principle ofres

judicatagenerally does not apply in cases hinging on the issue of citizenship. However, in

the case of Burca vs. Republic, an exception to this general rule was recognized. The

Court ruled in that case that in order that the doctrine of res judicatamay be applied in

cases of citizenship, the following must be present:

1) a persons citizenship be raised as a material issue in a controversy where said

person is a party;

2) the Solicitor General or his authorized representative took active part in the

resolution thereof, and

3) the finding on citizenship is affirmed by this Court.

AASJS v. DATUMANONG

Petitioner avers that Rep. Act No. 9225 is unconstitutional as it violates Section 5, Article IV

of the 1987 Constitution that states, "Dual allegiance of citizens is inimical to the national

interest and shall be dealt with by law."

PETITIONERS CONTENTION: Petitioner contends that Rep. Act No. 9225 cheapens

Philippine citizenship. He avers that Sections 2 and 3 of Rep. Act No. 9225, together, allowdual allegiance and not dual citizenship. Petitioner maintains that Section 2 allows all

Filipinos, either natural-born or naturalized, who become foreign citizens, to retain their

Philippine citizenship without losing their foreign citizenship. Section 3 permits dual

allegiance because said law allows natural-born citizens of the Philippines to regain their

Philippine citizenship by simply taking an oath of allegiance without forfeiting their foreign

allegiance. The Constitution, however, is categorical that dual allegiance is inimical to

the national interest.

From the above excerpts of the legislative record, it is clear that the intent of the

legislature in drafting Rep. Act No. 9225 is to do away with the provision in

Commonwealth Act No. 63 which takes away Philippine citizenship from natural-born

Filipinos who become naturalized citizens of other countries. What Rep. Act No. 9225does is allow dual citizenship to natural-born Filipino citizens who have lost Philippine

citizenship by reason of their naturalization as citizens of a foreign country. On its face, it

does not recognize dual allegiance. By swearing to the supreme authority of the

Republic, the person implicitly renounces his foreign citizenship. Plainly, from Section 3,

Rep. Act No. 9225 stayed clear out of the problem of dual allegiance and shifted the

burden of confronting the issue of whether or not there is dual allegiance to the

concerned foreign country. What happens to the other citizenship was not made a

concern of Rep. Act No. 9225.


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JACOT v. DAL

Petitioner was a natural born citizen of the Philippines, who became a naturalized citizen

of the US on 13 December 1989.

Petitioner sought to reacquire his Philippine citizenship under Republic Act No. 9225,otherwise known as the Citizenship Retention and Re-Acquisition Act. He filed a request

for the administration of his Oath of Allegiance to the Republic of the Philippines with the

Philippine Consulate General (PCG) of Los Angeles, California. The Los Angeles PCG

issued an Order of Approval4of petitioners request, and on the same day, petitioner

took his Oath of Allegiance to the Republic of the Philippines. On 27 September 2006, the

Bureau of Immigration issued Identification Certificate No. 06-12019 recognizing

petitioner as a citizen of the Philippines.

Six months after, on 26 March 2007, petitioner filed his Certificate of Candidacy for the

Position of Vice-Mayor of the Municipality of Catarman, Camiguin.

Respondent Rogen T. Dal filed a Petition for Disqualificationbefore the COMELEC

Provincial Office in Camiguin against petitioner, arguing that the latter failed to

renounce his US citizenship, as required under Section 5(2) of Republic Act No. 9225,

which reads as follows:

Section 5. Civil and Political Rights and Liabilities.Those who retain or reacquire Philippine

citizenship under this Act shall enjoy full civil and political rights and be subject to all

attendant liabilities and responsibilities under existing laws of the Philippines and the

following conditions:

x x x x

(2) Those seeking elective public office in the Philippines shall meet the qualifications for

holding such public office as required by the Constitution and existing laws and, at the

time of the filing of the certificate of candidacy, make a personal and sworn

renunciation of any and all foreign citizenship before any public officer authorized toadminister an oath.

RULING: Contrary to the assertions made by petitioner, his oath of allegiance to the

Republic of the Philippines made before the Los Angeles PCG and his Certificate of

Candidacy do not substantially comply with the requirement of a personal and sworn

renunciation of foreign citizenship because these are distinct requirements to be

complied with for different purposes.

Section 3 of Republic Act No. 9225requires that natural-born citizensof the Philippines,

who are already naturalized citizens of a foreign country, must take an oath of

allegiance to the Republic of the Philippines to reacquire or retain their Philippine

citizenship.

By the oath dictated in the afore-quoted provision, the Filipino swears allegiance to the

Philippines, but there is nothing therein on his renunciation of foreign citizenship. Precisely,

a situation might arise under Republic Act No. 9225 wherein said Filipino has dual

citizenship by also reacquiring or retaining his Philippine citizenship, despite his foreign

citizenship.

The afore-quoted oath of allegiance is substantially similar to the one contained in the


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Certificate of Candidacywhich must be executed by any personwho wishes to run for

public officein Philippine elections.

Now, Section 5(2) of Republic Act No. 9225 specifically requires persons seeking elective

public office, who either retained their Philippine citizenship or those who reacquired it,

to make a personal and sworn renunciation of any and all foreign citizenship before a

public officer authorized to administer an oath simultaneous with or before the filing ofthe certificate of candidacy.

Hence, Section 5(2) of Republic Act No. 9225compels natural-born Filipinos, who have

been naturalized as citizens of a foreign country, but who reacquired or retained their

Philippine citizenship (1) to take the oath of allegiance under Section 3 of Republic Act

No. 9225, and (2) for those seeking elective public offices in the Philippines , to

additionally execute a personal and sworn renunciationof any and all foreign citizenship

before an authorized public officer prior or simultaneous to the filing of their certificates

of candidacy, to qualify as candidates in Philippine elections.

Clearly Section 5(2) of Republic Act No. 9225 (on the making of a personal and sworn

renunciation of any and all foreign citizenship) requires of the Filipinos availing themselves

of the benefits under the said Act to accomplish an undertaking other than that which

they have presumably complied with under Section 3 thereof (oath of allegiance to the

Republic of the Philippines).

MANZANO AND VALLES, MISAPPLICATION: Petitioner erroneously invokes the doctrine in

VallesandMercado, wherein the filing by a person with dual citizenship of a certificate

of candidacy, containing an oath of allegiance, was already considered a renunciation

of foreign citizenship. The ruling of this Court in VallesandMercadois not applicable to

the present case, which is now specially governed by Republic Act No. 9225,

promulgated on 29 August 2003.

The Court in the aforesaid cases sought to define the term "dual citizenship" vis--visthe

concept of "dual allegiance." At the time this Court decided the cases of VallesandMercadoon 26 May 1999 and 9 August 2000, respectively, the more explicitly worded

requirements of Section 5(2) of Republic Act No. 9225 were not yet enacted by our

legislature.

DE GUZMAN V. DELA CRUZ

Petitioner De Guzman and private respondent Angelina DG. Dela Cruz were candidates

for vice-mayor of Guimba, Nueva Ecija in the May 14, 2007 elections. On April 3, 2007,

private respondent filed against petitioner a petition for disqualification docketed as SPA

No. 07-211, alleging that petitioner is not a citizen of the Philippines, but an immigrant

and resident of the United States of America.

In his answer, petitioner admitted that he was a naturalized American. However, on

January 25, 2006, he applied for dual citizenship under Republic Act No. 9225 (R.A. No.

9225), otherwise known as the Citizenship Retention and Re-Acquisition Act of 2003. Upon

approval of his application, he took his oath of allegiance to the Republic of the

Philippines on September 6, 2006. He argued that, having re-acquired Philippine

citizenship, he is entitled to exercise full civil and political rights.

R.A. No. 9225 was enacted to allow re-acquisition and retention of Philippine citizenship


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for: 1) natural-born citizens who have lost their Philippine citizenship by reason of their

naturalization as citizens of a foreign country; and 2) natural-born citizens of the

Philippines who, after the effectivity of the law, become citizens of a foreign country. The

law provides that they are deemed to have re-acquired or retained their Philippine

citizenship upon taking the oath of allegiance.

Petitioner falls under the first category, being a natural-born citizen who lost his Philippinecitizenship upon his naturalization as an American citizen. In the instant case, there is no

question that petitioner re-acquired his Philippine citizenship after taking the oath of

allegiance on September 6, 2006. However, it must be emphasized that R.A. No. 9225

imposes an additional requirement on those who wish to seek elective public office, as

follows: a personal and sworn renunciation of any and all foreign citizenship before any

public officer authorized to administer an oath.

Breaking down the afore-quoted provision, for a natural born Filipino, who reacquired or

retained his Philippine citizenship under Republic Act No. 9225, to run for public office, he

must: (1) meet the qualifications for holding such public office as required by the

Constitution and existing laws; and (2) make a personal and sworn renunciation of any

and all foreign citizenships before any public officer authorized to administer an oath.

Further, inJacot v. Dal and COMELEC, the Court ruled that a candidates oath of

allegiance to the Republic of the Philippines and his Certificate of Candidacy do not

substantially comply with the requirement of a personal and sworn renunciation of

foreign citizenship.

JAPZON V. COMELEC

Both petitioner Manuel B. Japzon (Japzon) and private respondent Jaime S. Ty (Ty) were

candidates for the Office of Mayor of the Municipality of General Macarthur, Eastern

Samar, in the local elections held on 14 May 2007.

On 15 June 2007, Japzon instituted SPA No. 07-568 by filing before the COMELEC aPetition to disqualify and/or cancel Tys Certificate of Candidacy on the ground of

material misrepresentation. Japzon averred in his Petition that Ty was a former natural-

born Filipino, having been born on 9 October 1943 in what was then Pambujan Sur,

Hernani Eastern Samar (now the Municipality of General Macarthur, Easter Samar) to

spouses Ang Chim Ty (a Chinese) and Crisanta Aranas Sumiguin (a Filipino). Ty eventually

migrated to the United States of America (USA) and became a citizen thereof. Ty had

been residing in the USA for the last 25 years.

While Ty may have applied for the reacquisition of his Philippine citizenship, Ty continued

to make trips to the USA, the most recent of which was on 31 October 2006 lasting until 20

January 2007. Moreover, although Ty already took his Oath of Allegiance to the Republic

of the Philippines, he continued to comport himself as an American citizen as proven byhis travel records. He had also failed to renounce his foreign citizenship as required by

Republic Act No. 9225, otherwise known as the Citizenship Retention and Reacquisition

Act of 2003, or related laws.

In his Answer, Ty alleged, among others, that he executed on 19 March 2007 a duly

notarized Renunciation of Foreign Citizenship.

RULING: There is no dispute that Ty was a natural-born Filipino. He was born and raised in


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the Municipality of General Macarthur, Eastern Samar, Philippines. However, he left to

work in the USA and eventually became an American citizen. On 2 October 2005, Ty

reacquired his Philippine citizenship by taking his Oath of Allegiance to the Republic of

the Philippines before Noemi T. Diaz, Vice Consul of the Philippine Consulate General in

Los Angeles, California, USA, in accordance with the provisions of Republic Act No. 9225.

At this point, Ty still held dual citizenship, i.e., American and Philippine. It was only on 19

March 2007 that Ty renounced his American citizenship before a notary public and,resultantly, became a pure Philippine citizen again.

It bears to point out that Republic Act No. 9225 governs the manner in which a natural-

born Filipino may reacquire or retainhis Philippine citizenship despite acquiring a foreign

citizenship, and provides for his rights and liabilities under such circumstances. A close

scrutiny of said statute would reveal that it does not at all touch on the matter of

residence of the natural-born Filipino taking advantage of its provisions.Republic Act No.

9225 imposes no residency requirement for the reacquisition or retention of Philippine

citizenship; nor does it mention any effect of such reacquisition or retention of Philippine

citizenship on the current residence of the concerned natural-born Filipino. Clearly,

Republic Act No. 9225 treats citizenship independently of residence. This is only logical

and consistent with the general intent of the law to allow for dual citizenship. Since a

natural-born Filipino may hold, at the same time, both Philippine and foreign citizenships,

he may establish residence either in the Philippines or in the foreign country of which he is

also a citizen.

For a natural born Filipino, who reacquired or retained his Philippine citizenship under

Republic Act No. 9225, to run for public office, he must: (1) meet the qualifications for

holding such public office as required by the Constitution and existing laws; and (2)

make a personal and sworn renunciation of any and all foreign citizenships before any

public officer authorized to administer an oath.

That Ty complied with the second requirement is beyond question. On 19 March 2007, he

personally executed a Renunciation of Foreign Citizenship before a notary public. By the

time he filed his Certificate of Candidacy for the Office of Mayor of the Municipality ofGeneral Macarthur, Eastern Samar, on 28 March 2007, he had already effectively

renounced his American citizenship, keeping solely his Philippine citizenship.

The other requirement of Section 5(2) of Republic Act No. 9225 pertains to the

qualifications required by the Constitution and existing laws.

CORDORA v. COMELEC

Tambunting does not deny that he is born of a Filipino mother and an American father.

Neither does he deny that he underwent the process involved in INS Form I-130 (Petition

for Relative) because of his fathers citizenship. Tambunting claims that because of his

parents differing citizenships, he is both Filipino and American by birth. Cordora, on theother hand, insists that Tambunting is a naturalized American citizen.

Tambunting possesses dual citizenship. Because of the circumstances of his birth, it was

no longer necessary for Tambunting to undergo the naturalization process to acquire

American citizenship. The process involved in INS Form I-130 only served to confirm the

American citizenship which Tambunting acquired at birth. The certification from the

Bureau of Immigration which Cordora presented contained two trips where Tambunting

claimed that he is an American. However, the same certification showed nine other trips


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where Tambunting claimed that he is Filipino. Clearly, Tambunting possessed dual

citizenship prior to the filing of his certificate of candidacy before the 2001 elections. The

fact that Tambunting had dual citizenship did not disqualify him from running for public

office.

Requirements for dual citizens from birth who desire to run for public office

We have to consider the present case in consonance with our rulings in Mercado v.

Manzano,Valles v. COMELEC,andAASJS v. Datumanong.Mercado and Valles involve

similar operative facts as the present case. Manzano and Valles, like Tambunting,

possessed dual citizenship by the circumstances of their birth. Manzano was born to

Filipino parents in the United States which follows the doctrine ofjus soli. Valles was born

to an Australian mother and a Filipino father in Australia. Our rulings inManzanoand

Vallesstated that dual citizenship is different from dual allegiance both by cause and, for

those desiring to run for public office, by effect. Dual citizenship is involuntary and arises

when, as a result of the concurrent application of the different laws of two or more

states, a person is simultaneously considered a national by the said states. Thus, like any

other natural-born Filipino, it is enough for a person with dual citizenship who seeks public

office to file his certificate of candidacy and swear to the oath of allegiance contained

therein.

Dual allegiance, on the other hand, is brought about by the individuals active

participation in the naturalization process.AASJS states that,under R.A. No. 9225, a

Filipino who becomes a naturalized citizen of another country is allowed to retain his

Filipino citizenship by swearing to the supreme authority of the Republic of the Philippines.

The act of taking an oath of allegiance is an implicit renunciation of a naturalized

citizens foreign citizenship.

In Sections 2 and 3 of R.A. No. 9225, the framers were not concerned with dual citizenship

per se, but with the status of naturalized citizens who maintain their allegiance to their

countries of origin even after their naturalization. Section 5(3) of R.A. No. 9225 states that

naturalized citizens who reacquire Filipino citizenship and desire to run for elective publicoffice in the Philippines shall "meet the qualifications for holding such public office as

required by the Constitution and existing laws and, at the time of filing the certificate of

candidacy, make a personal and sworn renunciation of any and all foreign citizenship

before any public officer authorized to administer an oath" aside from the oath of

allegiance prescribed in Section 3 of R.A. No. 9225. The twin requirements of swearing to

an Oath of Allegiance and executing a Renunciation of Foreign Citizenship served as the

bases for our recent rulings inJacot v. Dal and COMELEC, Velasco v. COMELEC, and

Japzon v. COMELEC, all of which involve natural-born Filipinos who later became

naturalized citizens of another country and thereafter ran for elective office in the

Philippines. In the present case, Tambunting, a natural-born Filipino, did not subsequently

become a naturalized citizen of another country. Hence, the twin requirements in R.A.

No. 9225 do not apply to him.

Sections 4 and 5 Citizenship

Documents

Transcript of Sections 4 and 5 Citizenship