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LABO vs.

COMELEC Case Digest


LABO vs. COMELEC
176 SCRA 1
Facts: Petitioner Ramon Labo, elected mayor of Baguio City was questioned on his citizenship. He
was married in the Philippines to an Australian citizen. The marriage was declared void in the
Australian Federal Court in Sydney on the ground that the marriage had been bigamous. According
to
Australian
records,
Labo
is
still
an
Australian
citizen.
Issue: Whether

or

not

Petitioner

Labo

is

citizen

of

the

Philippines.

Held: The petitioners contention that his marriage to an Australian national in 1976 did not
automatically 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, renouncing all other
allegiance. It does not appear in the record, nor does the petitioner claim, that he has reacquired
Philippine citizenship.

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