Article IV – Citizenship

ARTICLE IV - CITIZENSHIP 2. By naturalization

3. By marriage
What is citizenship?

 It is membership in a political community which is personal and more Note: Jus sanguinis and naturalization are the modes followed in the
or less permanent in character. Philippines.

Who is a citizen? What is the Caram Rule?

 According to Aristotle, citizens are persons who possess rights and  Chiongbian v. de Leon, under the 1935 Constitution, those born in the
who shares in the administration of justice, and in offices. Philippines of foreign parent, who before the adoption of the
Constitution had been elected to public office, are considered Filipino
Citizenship vs. Nationality citizens.
 In Tecson v. COMELEC, the 1935, Constitution, during which regime
 Nationality is membership in any class or form of political community.
FPJ had seen first light, confers citizenship to all persons whose fathers
Thus, nationals may be citizens [if members of a democratic
are Filipino citizens regardless of whether such children are legitimate
community] or subjects [if members of a monarchical community].
or illegitimate.
Nationality does not necessarily include the right or privilege of
exercising civil or political rights. “Those who are citizens of the Philippines at the time of the adoption of
this Constitution” – Filipino citizen
Section 1. The following are citizens of the Philippines: 1. Re: 1935 Constitution
o Sec. 4, Philippine Bill of 1902; Sec. 2, Jones Law of 1916
[1] Those who are citizens of the Philippines at the time of the adoption of
[including children born after April 11, 1899], Under these
this Constitution;
organic acts, inhabitants of the islands who were Spanish
[2] Those whose fathers or mothers are citizens of the Philippines; subjects on April 11, 1899, who did not opt in writing to retain
Spanish nationality between April 11, 1899 to October 11,
[3] Those born before January 17, 1973, of Filipino mothers, who elect 1900 — including their children — were deemed citizens of
Philippine citizenship upon reaching the age of majority; and the Philippines.
o Act No. 2927 [March 26,1920], then CA473, on naturalization
[4] Those who are naturalized in accordance with law.
[including children below 21 and residing in the Philippines at
the time of naturalization, as well as children born subsequent
to naturalization
What are the modes of acquiring citizenship? o Foreign women married to Filipino citizens before or after
1. By birth November 30, 1938 [effectivity of CA 473] who might
a) Jus sanguinis – acquisition of citizenship on the basis of blood themselves be lawfully naturalized
relationship. o Those benefited by the Roa doctrine applying the jus soli
b) Jus soli – acquisition of citizenship on the basis of the place of principle.
birth. o Caram provision.
o Those who elected Philippine citizenship.
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Article IV – Citizenship

2. Re: 1973 Constitution. - Those whose mothers are citizens of In Republic v. Lim, it was held that respondent, who was concededly an
thePhilippines. Provision is prospective in application; to benefit only illegitimate child considering that her Chinese father and Filipino mother were
those born on or after January 17, 1973 [date of effectivity of 1973 never married, is not required to comply with said constitutional and statutory
Constitution], requirements. Being an illegitimate child of a Filipino mother, respondent
became a Filipino upon birth. This notwithstanding, records show that the
“Those born before January 17, 1973, of Filipino mothers, who elect respondent elected Filipino citizenship when she reached the age of majority.
Philippine citizenship upon reaching the age of majority.” – considered She registered as a voter in Misamis Oriental when she was 18 years old. The
Filipino citizen exercise of the right of suffrage and the participation in election exercises
 Procedure for election. Election is expressed in a statement to be signed constitute a positive act of electing Philippine citizenship.
and sworn to by the party concerned before any official authorized to
administer oaths. Statement to be filed with the nearest Civil Registry.
The statement is to be accompanied with the Oath of Allegiance to the Section 2. Natural-born citizens are those who are citizens of the
Constitution and the Government of the Philippines [Sec. 1, CA 625]. Philippines from birth without having to perform any act to acquire or
 When to elect. Within three (3) years from reaching the age of majority perfect their Philippine citizenship. Those who elect Philippine citizenship
[Opinion, Secretary of Justice, s. 1948]; except when there is a in accordance with paragraph (3), Section 1 hereof shall be deemed
justifiable reason for the delay. natural-born citizens.
o In Co v. HRET, the Supreme Court affirmed the finding of the
HRET that the exercise of the right of suffrage and participation
in election exercises constitute a positive act of election of Who are natural born citizens?
Philippine citizenship. (doctrine of implied election)
o However, In Re: Ching, Bar Matter No. 914, where Ching, 1. Those who are citizens of the Philippines from birth without having to
having been born on April 11, 1964, was already 35 years old perform any act to acquire or perfect their Philippine citizenship.
when he complied with requirements of CA 625 on June 15, 2. Those born before January 17, 1973 of Filipino mothers, who elect
1999, or over 14 years after he had reached the age of majority. Philippine citizenship upon reaching age of majority.
By any reasonable yardstick, Ching’s election was clearly
Naturalization
beyond the allowable period within which to exercise the
privilege. All his mentioned acts cannot vest in him citizenship  The act of formally adopting a foreigner into the political body of a
as the law gives the requirement for election of Filipino nation by clothing him or her with the privileges of a citizen
citizenship which Ching did not comply with.
 The constitutional and statutory requirements of electing Filipino Modes of naturalization
citizenship apply only to legitimate children.
1. Direct: Citizenship is acquired by:
o If illegitimate, follow the citizenship of the mother.
(i) Individual, through judicial or administrative proceedings;
Additional note: The 1973 Constitution of the Republic of the Philippines, (In (ii) Special act of legislature;
Filipino: Ang Saligang Batas ng Pilipinas), ratified by the Citizens Assemblies on (iii) Collective change of nationality, as a result of cession or
January 17, 1973 subjugation; or
(iv) In some cases, by adoption of orphan minors as nationals of the
State where they are born.
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Article IV – Citizenship

2. Derivative: Citizenship conferred on: or race, or in any branches of education or industry for a
(i) Wife of naturalized husband; period of not less than 2 years; and
(ii) Minor children of naturalized person; or on the e. Born in the Philippines
(iii) Alien woman upon marriage to a national. 3. Character
a. Good moral character
Note: Derivative naturalization does not always follow as a matter of b. Believes in the Constitution
course, for it is usually made subject to stringent restrictions and c. Conducted himself in an irreproachable conduct during his
conditions. Our own laws, for instance, provide that an alien woman stay in the Philippines
married to a Filipino shall acquire his citizenship only if she herself might 4. Owns real estate in the Philippines not less than P5,000 in value; or has
be lawfully naturalized. some lucrative trade, profession or lawful occupation that can support
himself and his family
o In the Matter of the Petition of Ban Uan, lucrative trade,
Doctrine of indelible allegiance profession or lawful occupation means gainful employment. It
is not only that the person having the employment gets enough
 An individual may be compelled to retain his original nationality even if
for his ordinary necessities in life. It must be shown that the
he has already renounced or forfeited it under the laws of the second
employment gives one an income such that there is an
State whose nationality he has acquired.
appreciable margin of his income over his expenses as to be
Direct naturalization under Philippine laws able to provide for an adequate support in the event of
unemployment, sickness, or disability to work and thus avoid
 Under current and existing laws, there are three (3) ways by which an one's becoming the object of charity or a public charge
alien may become a citizen of the Philippines by naturalization:
a. judicial naturalization under Commonwealth Act No. 473, as And this qualification has been construed to mean, not only
amended; that he is not a beggar, a pauper or indigent, but, also, that his
b. administrative naturalization under Rep. Act No. 9139; and financial condition must be such as to permit him and the
c. legislative naturalization in the form of a law enacted by members of his family to live with reasonable comfort, in
Congress, bestowing Philippine citizenship to an alien. accordance with the prevailing standard of living, and
consistently with the demands of human dignity, at this stage
State the qualifications for judicial naturalization - CA 473 (A R C – R S E)
of our civilization.'"
1. Not less than 18 years of age on the date of hearing the petition (as
Note: While to be a student is a lawful occupation, it is not a lucrative one
amended by R.A. 6809);
and therefore comes short of the legal requirement. (Lim v. Republic)
2. Resided in the Philippines for not less than 10 years; may be reduced to
5 years, if; (O – I M – T B) 5. Speaks and writes English or Filipino and any principal Philippine
a. Honorably held office in the Philippines dialects (as amended by Sec. 6 Art. XIV); and
b. Established new industry or introduced a useful invention
c. Married to a Filipino woman Note: A deaf-mute cannot be naturalized.
d. Engaged as teacher in Philippine public or private school not 6. Enrolled minor children in any public or private school recognized by
established for exclusive instruction of a particular nationality the government where Philippine history, government and civics are
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Article IV – Citizenship

taught as part of the curriculum, during the entire period of residence o Purpose: to enable government to make initial investigations into
prior to hearing of petition. his circumstances to determine, his fitness for citizenship and to
test his sincerity.
Who are disqualified for naturalization? (P O D – S C W – R2) 2. Filing of the petition, accompanied by the affidavit of two credible
1. Polygamists or believers of polygamy persons, citizens of the Philippines, who personally know the
2. Persons opposed to organized government or affiliated with any petitioner, as character witnesses.
association or group of persons which uphold and teach doctrines 3. Publication of the petition. Under Sec. 9, Revised Naturalization Law, in
opposing all organized governments order that there be a valid publication, the following requisites must
3. Persons defending or teaching necessity or propriety of violence, concur:
personal assault or assassination for the success or predominance of a) the petition and notice of hearing must be published;
their ideas b) the publication must be made once a week for three
4. Persons suffering from mental alienation or incurable contagious consecutive weeks; and
disease c) the publication must be in the Official Gazette and in a
5. Persons convicted of crime involving moral turpitude newspaper of general circulation in the province where the
6. Citizens or subjects of nations with whom the Philippines is at war, applicant resides. In addition, copies of the petition and notice
during the period of such war of hearing must be posted in the office of the Clerk of Court or
7. Persons who, during residence in the Philippines, have not mingled in the building where the office is located. The same notice
socially with Filipinos, or did not evince sincere desire to learn and must also indicate, among others, the names of the witnesses
embrace customs, traditions and ideals of Filipinos whom the petitioner proposes to introduce at the trial
8. Citizens or subjects of a foreign country whose laws do not grant [Republic v. Michael Hong, G.R. No. 168877 March 23 2006],
Filipinos the right to become naturalized citizens or subjects thereof
(no reciprocity) o Publication is a jurisdictional requirement. Noncompliance is
fatal for it impairs the very root or foundation of the authority
Procedure for naturalization (I P P -R H D – A O) to decide the case, regardless of whether the one to blame is
the clerk of court or the petitioner or his counsel [Gan Tsitung
1. Filing of declaration of intention one year prior to the filing of the
v. Republic].
petition with the Office of the Solicitor General. The following are
o This rule applies equally to the determination of the sufficiency
exempt from filing declaration of intention:
of the contents of the notice of hearing and of the petition itself,
a) Born in the Philippines and have received their primary and
because an incomplete notice or petition, even if published, is
secondary education in public or private schools recognized by
no publication at all. Thus, in Sy v. Republic, it was held that
the Government and not limited to any race or nationality.
the copy of the petition to be posted and published should be a
b) Resided in the Philippines for 30 years or more before the
textual or verbatim restatement of the petition filed.
filing of the petition, and enrolled his children in elementary
o In the same vein, the failure to state all the required details in
and high schools recognized by the Government and not
the notice of hearing, like the names of applicant’s witnesses,
limited to any race or nationality.
constitutes a fatal defect. The publication of the affidavit of
c) Widow and minor children of an alien who has declared his
such witnesses did not cure the omission of their names in the
intention to become a citizen of the Philippines and dies before
notice of hearing. It is a settled rule that naturalization laws
he is actually naturalized.
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Article IV – Citizenship

should be rigidly enforced and strictly construed in favour of naturalization

the government and against the applicant [Ong Chua v. If not residing in the Phil. At the time GR: Considered citizen only during
Republic]. of naturalization minority
4. Actual residence in the Philippines during the entire proceedings. XPN: He begins to reside
5. Hearing of the petition. permanently in the Phil.
6. Promulgation of the decision. After parents’ naturalization
7. Hearing after two years. At this hearing, the applicant shall show that Considered Filipino, provided registered as such before any Phil. consulate
during the two-year probation period, applicant has within 1 year after attaining majority age and takes oath of allegiance.
a) not left the Philippines;
b) dedicated himself continuously to a lawful calling or profession What are the grounds for denaturalization? (F R I G D)
c) not been convicted of any offense or violation of rules; and
d) not committed an act prejudicial to the interest of the nation or 1. Naturalization certificate obtained fraudulently or illegally
contrary to any Government- announced policies. 2. If, within 5 years, he returns to his native country or to some foreign
8. Oath taking and issuance of the Certificate of Naturalization. country and establishes residence therein
3. Naturalization obtained through invalid declaration of intention
 In Republic v. Dela Rosa, it is not for an applicant to decide for himself 4. Minor children failed to graduate through the fault of parents either by
and to select the requirement which he believes, even sincerely, are neglecting support or by transferring them to another school
applicable to his case and discard those which be believes are 5. Allowing himself to be used as a dummy.
inconvenient or merely of nuisance value. The law does not distinguish
What are the effects of denaturalization?
between an applicant who was formerly a Filipino citizen and one who
was never such a citizen. It does not provide a special procedure for the 1. If ground affects intrinsic validity of proceedings, denaturalization shall
reacquisition of Philippine citizenship by former Filipino citizens akin divest wife and children of their derivative naturalization
to the repatriation of a woman who had lost her Philippine citizenship 2. If the ground is personal, the wife and children shall retain citizenship.
by reason of her marriage to an alien.
Special committee on naturalization ( RA 9319)
What are the effects of naturalization?
1. Composed of the Solicitor General, as chairman,
On the wife 2. the Secretary of Foreign Affairs or his representative, and
In Moy Ya Lim Yao v. Comm. of Immigration, it vests citizenship on the 3. the National Security Adviser, as members,
wife who might herself be lawfully naturalized; She need not prove her  this Committee has the power to approve, deny or reject applications
qualifications but only that she is not disqualified. All she has to do is to file for naturalization under this Act.
before the Bureau of Immigration and Deportation a petition for the
cancellation of her Alien Certificate of Registration (ACR).
On the minor children
Born in the Philippines Section 3. Philippine citizenship may be lost or reacquired in the manner
Automatically becomes a citizen provided by law.
Born Abroad
Before the naturalization of the father
If residing in the Phil. At the time of Automatically becomes a citizen.
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Article IV – Citizenship

Section 4. Citizens of the Philippines who marry aliens shall retain their that I will support and defend the Constitution of the Republic of the
citizenship, unless by their act or omission, they are deemed, under the Philippines and obey the laws and legal orders promulgated by the duly
law, to have renounced it. constituted authorities of the Philippines; and I hereby declare that I
recognize and accept the supreme authority of the Philippines and will
maintain true faith and allegiance thereto; and that I impose this
What are the grounds for loss of Philippine citizenship? (N E O – C A D – M) obligation upon myself voluntarily, without mental reservation or
purpose of evasion.”
1. Naturalization in a foreign country  Sec. 4, R.A. 9225 - The unmarried child, whether legitimate,
2. Express renunciation of citizenship (expatriation); or illegitimate or adopted, below 18 years of age, of those who reacquire
3. Subscribing to an oath of allegiance to the constitution or laws of a Philippine citizenship upon the effectivity of this Act shall be deemed
foreign country upon attaining 21 years of age; or citizens of the Philippines .
4. Cancellation of certificate of naturalization; or
5. Rendering service to or accepting commission in the armed forces of a By express renunciation of citizenship
foreign country; or  Express renunciation means a renunciation that is made known
6. Having been declared by final judgment a deserter of the armed forces distinctly and explicitly, and not left to inference or implication
of the Philippines in times of war.  In Yu v. Defensor-Santiago, where obtention of a Portuguese passport
7. In case of a woman, upon her marriage, to a foreigner if, by virtue of the and signing of commercial documents as a Portuguese were construed
laws in force in her husband’s country, she acquires his nationality. as renunciation of Philippine citizenship.
Naturalization in a foreign country  In Mercado v. Manzano, the mere application or possession of an alien
certificate of registration does not amount to renunciation.
 In Frivaldo v. COMELEC, if he really wanted to disavow his American  In Labo v. COMELEC, it was held that Labo lost Filipino citizenship
citizenship and reacquire Philippine citizenship, the petitioner should because he expressly renounced allegiance to the Philippines when he
have done so in accordance with the laws of our country. Under CA No. applied for Australian citizenship.
63 as amended by CA No. 473 and PD No. 725, Philippine citizenship
may be reacquired by direct act of Congress, by naturalization, or by Subscribing to an oath of allegiance to support the Constitution or laws of
repatriation. a foreign country upon attaining 21 years of age
 However, this is modified by R.A. 9225, entitled An Act Making the  Provided, however, Filipino may not divest himself of Philippine
Citizenship of Philippine Citizens Who Acquire Foreign Citizenship citizenship in any manner while the Republic of the Philippines is at
Permanent (which took effect September 17, 2003), which declares the war with any country.
policy of the State that all Philippine citizens who become citizens of  The proviso that a Filipino may not divest himself of Philippine
another country shall be deemed not to have lost their Philippine citizenship in this manner while the Republic of the Philippines is at
citizenship under the conditions of this Act. war with any country may be considered as an application of the
 Sec. 3, R.A. 9225 provides Natural-born citizens of the Philippines principle of indelible allegiance.
who have lost their Philippine citizenship by reason of their
naturalization as citizens of a foreign country are deemed to have Bv rendering service to or accepting commission in the armed forces of a
reacquired Philippine citizenship upon taking the following oath of foreign country
allegiance to the Republic: ________________ , solemnly swear (or affirm)

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Article IV – Citizenship

 Provided, that the rendering of service to, or acceptance of such a) oath of allegiance to the Republic of the Philippines and
commission in, the armed forces of a foreign country and the taking of b) registration in the proper civil registry and in the Bureau of
an oath of allegiance incident thereto, with consent of the Republic of Immigration.
the Philippines, shall not divest a Filipino of his Philippine citizenship if
either of the following circumstances is present: The Bureau of Immigration shall thereupon cancel the pertinent
a) The Republic of the Philippines has a defensive and/or alien certificate of registration and issue the certificate of
offensive pact of alliance with the said foreign country; or identification as Filipino citizen to the repatriated citizen.
b) The said foreign country maintains armed forces in Philippine What is the effect of repatriation?
territory with the consent of the Republic of the Philippines.
 In Bengzon v. HRET, repatriation results in the recovery of the original
Bv having been declared bv competent authority a deserter of the nationality. This means that a naturalized Filipino who lost his
Philippine armed forces in time of war citizenship will be restored to his prior status as a naturalized Filipino
 Unless subsequently, a plenary pardon or amnesty has been granted. citizen. On the other hand, if he was originally a natural‐born citizen
before he lost his Philippine citizenship, he will be restored to his
Marriage by Filipino to an alien former status as a natural‐born Filipino.

 “Citizens of the Philippines who marry aliens shall retain their What is an example of reacquisition of citizenship by the direct act of
citizenship, unless by their act or omission they are deemed, under the congress?
law, to have renounced it” [Sec. 4, Art. IV].
 R.A. 9225 also known as the “Citizenship Retention and Re‐acquisition
What are the ways to reacquire citizenship? Act of 2003,” approved on August 29, 2003 provides that, upon taking
the oath of allegiance to the Republic:
1. Naturalization, provided that the applicant possesses none of the 1. Natural‐born citizens of the Philippines who have lost their
disqualifications prescribed for naturalization. naturalization as citizens of a foreign country are deemed to
2. Repatriation have re‐acquired Philippine citizenship; and
3. Direct act of Congress 2. Natural‐born citizens of the Philippines who, after the
R.A. 8171 is an act providing for the repatriation of: effectivity of said RA, become citizens of a foreign country shall
retain their Philippine citizenship.
1. Filipino women who have lost their Philippine citizenship by marriage
to aliens; and Note: Read case of Grace poe.
2. Natural-born Filipinos who have lost their Philippine citizenship on Attack on one’s citizenship
account of political or economic necessity
 In Co v. HRET, attack on one’s citizenship may be made only through a
(Sec. 1, RA 8171) direct, not a collateral proceeding.
How is repatriation effected? Does Res judicata set in cases involving citizenship?
 Sec.2, RA 8171. Repatriation shall be effected by taking the necessary  General Rule: No.
 Exceptions:
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Article IV – Citizenship

a. Person’s citizenship is resolved by a court or an administrative Furthermore, for candidates with dual citizenship, it is enough that they
body as a material issue in the controversy, after a full-blown elect Philippine citizenship upon the filing of their certificate of
hearing; candidacy to terminate their status as persons with dual citizenship.
b. With the active participation of the Solicitor General or his The filing of a certificate of candidacy suffices to renounce foreign
representative; and citizenship, effectively removing any disqualification as dual citizen.
c. The finding of his citizenship is affirmed by the Supreme Court. 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
Then the decision on the matter shall constitute conclusive proof of Constitution and will maintain true faith and allegiance to the same.
such party’s citizenship in any other case or proceeding. Such declaration under oath operates as an effective renunciation of
foreign citizenship
 However, this doctrine Mercado that the filing of a certificate of
Section 5. Dual allegiance of citizens is inimical to the national interest and candidacy suffices to renounce foreign citizenship does not apply to one
shall be dealt with by law. who, after having reacquired Philippine citizenship under R.A. 9225,
runs for public office. To comply with the provisions of Sec. 5 (2) of R.A.
9225, it is necessary that the candidate for public office must state in
Dual Citizenship v. Dual Allegiance clear and unequivocal terms that he is renouncing all foreign
citizenship.
Dual Citizenship Dual Allegiance  Sec. 5, Art. IV of the Constitution is a declaration of policy and it is not a
Arises when, as a result of Refers to the situation where a self-executing provision. The legislature still has to enact the law on
concurrent application of the person simultaneously owes, by dual allegiance.
different laws of two or more States, some positive act, loyalty to two or
a person is simultaneously more States. Other notes:
considered a citizen of said states.
 The use of two passports means a person does not renounce his citizenship in other
Involuntary Result of an individual’s volition and
country.
is prohibited by the Constitution.
Q: Are persons possessing dual citizenship by virtue of birth barred from running for
public office?
Policy against dual allegiance
 No, the fact that a person has dual citizenship does not disqualify him from running
 In Mercado v. Manzano, the Court clarified the “dual citizenship” for public office. (Cordora v. COMELEC, G.R. No. 176947, Feb. 19, 2009)
disqualification in Sec. 40, Local Government Code, and reconciled the
Q: A, a naturalized US citizen, sought to reacquire his Philippine citizenship. He took his
same with Sec. 5, Art. IV of the Constitution on “dual allegiance”. oath of allegiance to the Republic of the Philippines before the Vice Consul. He then ran
Recognizing situations in which a Filipino citizen may, without and won as Vice Mayor of a municipality. The COMELEC, however, disqualified him on
performing any act and as an involuntary consequence of the the ground that he failed to renounce his US citizenship.
conflicting laws of different countries, be also a citizen of another state,
Is A disqualified from running as a candidate in the local elections for his failure to
the Court explained that “dual citizenship” as a disqualification must make a personal and sworn renunciation of his US citizenship?
refer to citizens with “dual allegiance”. Consequently, persons with
mere dual citizenship do not fall under the disqualification.  A: Yes. Section 5(2) of R.A. 9225 (on the making of a personal and sworn
renunciation of any and all foreign citizenship) requires the Filipinos availing

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Article IV – Citizenship

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). There is little doubt, therefore, that
the intent of the legislators was not only for Filipinos reacquiring or retaining their
Philippine citizenship under R.A. 9225 to take their oath of allegiance to the
Republic of the Philippines, but also to explicitly renounce their foreign citizenship if
they wish to run for elective posts in the Philippines. To qualify as a candidate in
Philippine elections, Filipinos must only have one citizenship, namely, Philippine
citizenship.

The oath of allegiance contained in the Certificate of Candidacy, does not constitute
the personal and sworn renunciation sought under Section 5(2) of R.A. No. 9225. It
bears to emphasize that the said oath of allegiance is a general requirement for all
those who wish to run as candidates in Philippine elections; while the renunciation
of foreign citizenship is an additional requisite only for those who have retained or
reacquired Philippine citizenship under R.A. No. 9225 and who seek elective public
posts, considering their special circumstance of having more than one citizenship.
(Jacot v. Dal, G.R. No. 179848, Nov.27, 2008)

Q: A” is a naturalized citizen of another country who reacquires Filipino citizenship. On

the other hand, “B” possesses dual citizenship by birth. If they desire to run for elective
public office, what requirement must they comply as regards their citizenship?

 A must comply with the requirements set in R.A 9225. Sec 5(3) of R.A. 9225 states
that naturalized citizens who reacquire Filipino citizenship and desire to run for
public office shall “…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. 9225.

B need not comply with the twin requirements of swearing an oath of allegiance and
executing a renunciation of foreign citizenship because he is a natural‐born Filipino
who did not subsequently become a naturalized citizen of another country. It is
sufficed, if upon the filing of his certificate of candidacy, he elects Philippine
citizenship to terminate his status as person with dual citizenship considering that
his condition in the unavoidable consequence of conflicting laws of different States.
(Cordora v. COMELEC, G.R. No. 176947, Feb. 19, 2009)