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    Mercado VS Manzano

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    Gillian Calpito
    This case involved a petition to disqualify Eduardo Manzano from running for vice mayor of Makati City due to his alleged dual citizenship as both a Filipino and American. The Supreme Court ruled that Manzano was not disqualified. [1] While Manzano had dual citizenship under Philippine and U.S. laws due to his parents' nationalities and place of birth, dual citizenship alone does not constitute dual allegiance prohibited under law. [2] By declaring himself a Filipino citizen in his certificate of candidacy and renouncing any foreign allegiance, Manzano effectively repudiated any U.S. citizenship. [3] Manzano's lifelong ties to the Philippines through education, profession

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    Mercado VS Manzano

    Uploaded by

    Gillian Calpito
    58 views2 pages
    This case involved a petition to disqualify Eduardo Manzano from running for vice mayor of Makati City due to his alleged dual citizenship as both a Filipino and American. The Supreme Court ruled that Manzano was not disqualified. [1] While Manzano had dual citizenship under Philippine and U.S. laws due to his parents' nationalities and place of birth, dual citizenship alone does not constitute dual allegiance prohibited under law. [2] By declaring himself a Filipino citizen in his certificate of candidacy and renouncing any foreign allegiance, Manzano effectively repudiated any U.S. citizenship. [3] Manzano's lifelong ties to the Philippines through education, profession

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    This case involved a petition to disqualify Eduardo Manzano from running for vice mayor of Makati City due to his alleged dual citizenship as both a Filipino and American. The Supreme Court ruled that Manzano was not disqualified. [1] While Manzano had dual citizenship under Philippine and U.S. laws due to his parents' nationalities and place of birth, dual citizenship alone does not constitute dual allegiance prohibited under law. [2] By declaring himself a Filipino citizen in his certificate of candidacy and renouncing any foreign allegiance, Manzano effectively repudiated any U.S. citizenship. [3] Manzano's lifelong ties to the Philippines through education, profession

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    58 views2 pages

    Mercado VS Manzano

    Uploaded by

    Gillian Calpito
    This case involved a petition to disqualify Eduardo Manzano from running for vice mayor of Makati City due to his alleged dual citizenship as both a Filipino and American. The Supreme Court ruled that Manzano was not disqualified. [1] While Manzano had dual citizenship under Philippine and U.S. laws due to his parents' nationalities and place of birth, dual citizenship alone does not constitute dual allegiance prohibited under law. [2] By declaring himself a Filipino citizen in his certificate of candidacy and renouncing any foreign allegiance, Manzano effectively repudiated any U.S. citizenship. [3] Manzano's lifelong ties to the Philippines through education, profession

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    Mercado v.

    Manzano

    FACTS:
    Petitioner Ernesto S. Mercado and private respondent Eduardo B.
    Manzano were candidates for vice mayor of the City of Makati in the May
    11, 1998 elections. Respondent Manzano garnered the highest votes but
    his proclamation was suspended because of a petition for disqualification
    was filed on the ground that the respondent is an American citizen based
    on the record of the Bureau of Immigration and misrepresented himself as
    a natural-born Filipino citizen. Respondent Manzano alleged that that he
    is a Filipino citizen because he was born in 1955 of a Filipino father and a
    Filipino mother and also considered an American citizen under US Laws
    where he was born. Since the Philippines adheres to the principle of jus
    sanguinis, while the United States follows the doctrine of jus soli,
    Respondent Manzano is a national both of the Philippines and of the
    United States.

    ISSUE:
    Whether or not Manzano is disqualified for the elective position of vice-
    mayor

    HELD:
    No. The disqualification of private respondent Manzano is being sought
    under Local Government Code of 1991 RA7160, which declares as
    "disqualified from running for any elective local position: . . . (d) Those with
    dual citizenship." The Court ruled that the phrase "dual citizenship" must be
    understood as referring to "dual allegiance." Consequently, persons with
    mere dual citizenship do not fall under this disqualification.

    Dual citizenship is different from dual allegiance.


    Dual citizenship: 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
    Example: a person whose parents are citizens of a state which
    adheres to the principle of jus sanguinis is born in a state which
    follows the doctrine of jus soli. Such a person without any voluntary
    act on his part, is considered a citizen of both states.

    Dual allegiance: 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 individual’s volition.
    The Court ruled that the filing of such certificate of candidacy sufficed to
    renounce his American citizenship. 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.

    On the other hand, private respondent's 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.

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