Mercado Vs Manzano Digest
Mercado Vs Manzano Digest
Mercado Vs Manzano Digest
FACTS: Edu Manzano and Ernesto Mercado were candidates for Vice-Mayor of Makati City during 1998 election.
Manzano got the highest number of votes; however, the proclamation was suspended due to the disqualification
petition filed against him. The petition alleges that Manzano is not a citizen of the Philippines but rather of United States
of America. In his answer, Manzano argued that he is a Filipino Citizen because he was born of Filipino parents but since
he was born in the U.S., he is still considered an American citizen under US laws. Sec. 40(d) of the Local Government
Code provides that those holding dual citizenship are disqualified from running for any elective position.
ISSUES: WON Manzano is qualified to run for and/or hold elective office in view of his dual citizenship
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.”