Maquiling vs COMELEC

Manzano vs COMELEC

Respondent Arnado is a natural born Filipino

citizen

Respondent Edu is a natural born Filipino

citizen by operation of the 1935 Philippine
Constitution, as his father and mother were
Filipinos at the time of his birth. He acquired
US citizenship by operation of the United
States Constitution and laws under the
principle of jus soli.

Acquired US citizenship by naturalization.

He acquired US citizenship by operation of the

United States Constitution and laws under the
principle of jus soli. (INVOLUNTARY)

(Result of his own volition)

As a consequence of his subsequent

naturalization as a citizen of the United States
of America, he lost his Filipino citizenship.

His parents also registered him as an alien with

the Philippine Bureau of Immigration. He was
issued an alien certificate of registration. This,
however, did not result in the loss of his
Philippine citizenship, as he did not renounce
Philippine citizenship and did not take an oath
of allegiance to the United States.

Arnado applied for repatriation under Republic Did not applied for repatriation as he did not
Act (R.A.) No. 9225 before the Consulate
lost his Philippine Citizenship
General of the Philippines in San Franciso,
USA and took the Oath of Allegiance to the
Republic of the Philippines on 10 July
2008.4 On the same day an Order of Approval
of his Citizenship Retention and Re-acquisition
was issued in his favor
Both ran for public office
Arnado voluntarily and effectively reverted
Did not do any act to revert his earlier status as
to his earlier status as a dual citizen by using a dual citizen.
a US passport after renouncing ones foreign
citizenship
Dual Allegiance
Dual Citizenship
By the time he filed his certificate of candidacy By declaring in his certificate of candidacy that
on 30 November 2009, Arnado was a dual
he is a Filipino citizen; that he is not a
citizen enjoying the rights and privileges of
permanent resident or immigrant of another
Filipino and American citizenship. He was
country; that he will defend and support the
qualified to vote, but by the express
Constitution of the Philippines and bear true
disqualification under Section 40(d) of the
faith and allegiance thereto and that he does so
Local Government Code, he was not qualified without mental reservation, private respondent
to run for a local elective position.
has, as far as the laws of this country are
concerned, effectively repudiated his American
In effect, Arnado was solely and exclusively a citizenship and anything which he may have
said before as a dual citizen.
Filipino citizen only for a period of eleven
days, or from 3 April 2009 until 14 April 2009,
on which date he first used his American
There being no disqualifications, he is
passport after renouncing his American
qualified to run for elective position.
citizenship.
what the law prohibits is dual allegiance and not dual citizenship.