SECTION 4.

Citizens of the Philippines who marry aliens shall retain their citizenship, unless
by their act or omission they are deemed, under the law, to have renounced it.
LABO V. COMELEC
The petitioner's 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, both quoted above. Renouncing all other allegiance, he
swore "to be faithful and bear true allegiance to Her Majesty Elizabeth the Second,
Queen of Australia ..." and to fulfill his duties "as an Australian citizen."
Even if it be assumed that, as the petitioner asserts, his naturalization in Australia was
annulled after it was found that his marriage to the Australian citizen was bigamous, that
circumstance alone did not automatically restore his Philippine citizenship. His divestiture
of Australian citizenship does not concern us here. That is a matter between him and his
adopted country. What we must consider is the fact that he voluntarily and freely
rejected Philippine citizenship and willingly and knowingly embraced the citizenship of a
foreign country. The possibility that he may have been subsequently rejected by
Australia, as he claims, does not mean that he has been automatically reinstated as a
citizen of the Philippines.
DJUMANTAN V. DOMINGO
The fact of marriage by an alien to a citizen does not withdraw her from the operation of
the immigration laws governing the admission and exclusion of aliens. Marriage of an
alien woman to a Filipino husband does not ipso facto make her a Filipino citizen and
does not excuse her from her failure to depart from the country upon the expiration of
her extended stay here as an alien.
MERCADO V. MANZANO
Petitioner Mercado and private respondent Manzano were candidates for vice mayor of
the City of Makati in the May 11, 1998 elections. The proclamation of private respondent
was suspended in view of a pending petition for disqualification filed by a certain Ernesto
Mamaril who alleged that private respondent was not a citizen of the Philippines but of
the United States. The Second Division of the COMELEC granted the petition of Mamaril
and ordered the cancellation of the certificate of candidacy of private respondent on
the ground that he is a dual citizen and under Sec. 40 of the Local Government Code,
persons with dual citizenship are disqualified from running for any elective position.
ON DUAL ALLEGIANCE: The disqualification of private respondent Manzano is being
sought under 40 of the Local Government Code of 1991 (R.A. No. 7160), which declares
as disqualified from running for any elective local position: . . . (d) Those with dual
citizenship. This provision is incorporated in the Charter of the City of Makati.
Invoking the maxim dura lex sed lex, petitioner, as well as the Solicitor General, who sides
with him in this case, contends that through 40(d) of the Local Government Code,

Congress has command[ed] in explicit terms the ineligibility of persons possessing dual
allegiance to hold local elective office.
To begin with, dual citizenship is different from dual allegiance. The former arises when, as
a 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. For instance, such a situation
may arise when 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, ipso facto and without any voluntary act on his part, is concurrently considered a
citizen of both states.
Considering the citizenship clause (Art. IV) of our Constitution, it is possible for the
following classes of citizens of the Philippines to possess dual citizenship:
(1) Those born of Filipino fathers and/or mothers in foreign countries which follow
the principle of jus soli;
(2) Those born in the Philippines of Filipino mothers and alien fathers if by the laws
of their fathers country such children are citizens of that country;
(3) Those who marry aliens if by the laws of the latters country the former are
considered citizens, unless by their act or omission they are deemed to have
renounced Philippine citizenship.
There may be other situations in which a citizen of the Philippines may, without
performing any act, be also a citizen of another state; but the above cases are clearly
possible given the constitutional provisions on citizenship.
Dual allegiance, on the other hand, 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 individuals volition.
Clearly, in including 5 in Article IV on citizenship, the concern of the Constitutional
Commission was not with dual citizens per se but with naturalized citizens who maintain
their allegiance to their countries of origin even after their naturalization. Hence, the
phrase dual citizenship in R.A. No. 7160, 40(d) and in R.A. No. 7854, 20 must be
understood as referring to dual allegiance. Consequently, persons with mere dual
citizenship do not fall under this disqualification. Unlike those with dual allegiance, who
must, therefore, be subject to strict process with respect to the termination of their status,
for candidates with dual citizenship, it should suffice if, upon the filing of their certificates
of candidacy, they elect Philippine citizenship to terminate their status as persons with
dual citizenship considering that their condition is the unavoidable consequence of
conflicting laws of different states. As Joaquin G. Bernas, one of the most perceptive
members of the Constitutional Commission, pointed out: [D]ual citizenship is just a reality
imposed on us because we have no control of the laws on citizenship of other countries.
We recognize a child of a Filipino mother. But whether or not she is considered a citizen
of another country is something completely beyond our control.
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 respondents 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.
His declarations will be taken upon the faith that he will fulfill his undertaking made under
oath. Should he betray that trust, there are enough sanctions for declaring the loss of his
Philippine citizenship through expatriation in appropriate proceedings.
VALLES V. COMELEC
Rosalind Ybasco Lopez was born on May 16, 1934 in Napier Terrace, Broome, Western
Australia, to the spouses, Telesforo Ybasco, a Filipino citizen and native of Daet,
Camarines Norte, and Theresa Marquez, an Australian. In 1949, at the age of fifteen, she
left Australia and came to settle in the Philippines.
On June 27, 1952, she was married to Leopoldo Lopez, a Filipino citizen, at the Malate
Catholic Church in Manila. Since then, she has continuously participated in the electoral
process not only as a voter but as a candidate, as well. She served as Provincial Board
Member of the Sangguniang Panlalawigan of Davao Oriental. In 1992, she ran for and
was elected governor of Davao Oriental. Her election was contested by her opponent,
Gil Taojo, Jr., in a petition for quo warranto, docketed as EPC No. 92-54, alleging as
ground therefor her alleged Australian citizenship.
In the aforecited case of Mercado vs. Manzano, the Court clarified dual citizenship as
used in the Local Government Code and reconciled the same with Article IV, Section 5
of the 1987 Constitution on dual allegiance. Recognizing situations in which a Filipino
citizen may, without performing any act, and as an involuntary consequence of the
conflicting laws of different countries, be also a citizen of another state, the Court
explained that dual citizenship as a disqualification must refer to citizens with dual
allegiance. The Court succinctly pronounced:
xxx the phrase dual citizenship in R.A. No. 7160, xxx 40 (d) and in R.A. No. 7854, xxx
20 must be understood as referring to dual allegiance. Consequently, persons
with mere dual citizenship do not fall under this disqualification.
Thus, the fact that the private respondent had dual citizenship did not automatically
disqualify her from running for a public office. Furthermore, it was ruled that for
candidates with dual citizenship, it is enough that they elect Philippine citizenship upon
the filing of their certificate of candidacy, to terminate their status as persons with dual
citizenship. The filing of a certificate of candidacy sufficed to renounce foreign
citizenship, effectively removing any disqualification as a dual citizen. 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 Constitution of the Philippines and will maintain true
faith and allegiance thereto. Such declaration, which is under oath, operates as an
effective renunciation of foreign citizenship. Therefore, when the herein private
respondent filed her certificate of candidacy in 1992, such fact alone terminated her
Australian citizenship.
Then, too, it is significant to note that on January 15 1992, private respondent executed a
Declaration of Renunciation of Australian Citizenship, duly registered in the Department
of Immigration and Ethnic Affairs of Australia on May 12, 1992. And, as a result, on

February 11, 1992, the Australian passport of private respondent was cancelled, as
certified to by Second Secretary Richard F. Munro of the Embassy of Australia in Manila.
As aptly appreciated by the COMELEC, the aforesaid acts were enough to settle the
issue of the alleged dual citizenship of Rosalind Ybasco Lopez. Since her renunciation
was effective, petitioners claim that private respondent must go through the whole
process of repatriation holds no water.
Petitioner maintains further that when citizenship is raised as an issue in judicial or
administrative proceedings, the resolution or decision thereon is generally not considered
res judicata in any subsequent proceeding challenging the same; citing the case of Moy
Ya Lim Yao vs. Commissioner of Immigration.
Petitioner is correct insofar as the general rule is concerned, i.e. the principle of res
judicata generally does not apply in cases hinging on the issue of citizenship. However, in
the case of Burca vs. Republic, an exception to this general rule was recognized. The
Court ruled in that case that in order that the doctrine of res judicata may be applied in
cases of citizenship, the following must be present:
1) a persons citizenship be raised as a material issue in a controversy where said
person is a party;
2) the Solicitor General or his authorized representative took active part in the
resolution thereof, and
3) the finding on citizenship is affirmed by this Court.
AASJS v. DATUMANONG
Petitioner avers that Rep. Act No. 9225 is unconstitutional as it violates Section 5, Article IV
of the 1987 Constitution that states, "Dual allegiance of citizens is inimical to the national
interest and shall be dealt with by law."
PETITIONERS CONTENTION: Petitioner contends that Rep. Act No. 9225 cheapens
Philippine citizenship. He avers that Sections 2 and 3 of Rep. Act No. 9225, together, allow
dual allegiance and not dual citizenship. Petitioner maintains that Section 2 allows all
Filipinos, either natural-born or naturalized, who become foreign citizens, to retain their
Philippine citizenship without losing their foreign citizenship. Section 3 permits dual
allegiance because said law allows natural-born citizens of the Philippines to regain their
Philippine citizenship by simply taking an oath of allegiance without forfeiting their foreign
allegiance. The Constitution, however, is categorical that dual allegiance is inimical to
the national interest.
From the above excerpts of the legislative record, it is clear that the intent of the
legislature in drafting Rep. Act No. 9225 is to do away with the provision in
Commonwealth Act No. 63 which takes away Philippine citizenship from natural-born
Filipinos who become naturalized citizens of other countries. What Rep. Act No. 9225
does is allow dual citizenship to natural-born Filipino citizens who have lost Philippine
citizenship by reason of their naturalization as citizens of a foreign country. On its face, it
does not recognize dual allegiance. By swearing to the supreme authority of the
Republic, the person implicitly renounces his foreign citizenship. Plainly, from Section 3,
Rep. Act No. 9225 stayed clear out of the problem of dual allegiance and shifted the
burden of confronting the issue of whether or not there is dual allegiance to the
concerned foreign country. What happens to the other citizenship was not made a
concern of Rep. Act No. 9225.

JACOT v. DAL
Petitioner was a natural born citizen of the Philippines, who became a naturalized citizen
of the US on 13 December 1989.
Petitioner sought to reacquire his Philippine citizenship under Republic Act No. 9225,
otherwise known as the Citizenship Retention and Re-Acquisition Act. He filed a request
for the administration of his Oath of Allegiance to the Republic of the Philippines with the
Philippine Consulate General (PCG) of Los Angeles, California. The Los Angeles PCG
issued an Order of Approval4 of petitioners request, and on the same day, petitioner
took his Oath of Allegiance to the Republic of the Philippines. On 27 September 2006, the
Bureau of Immigration issued Identification Certificate No. 06-12019 recognizing
petitioner as a citizen of the Philippines.
Six months after, on 26 March 2007, petitioner filed his Certificate of Candidacy for the
Position of Vice-Mayor of the Municipality of Catarman, Camiguin.
Respondent Rogen T. Dal filed a Petition for Disqualificationbefore the COMELEC
Provincial Office in Camiguin against petitioner, arguing that the latter failed to
renounce his US citizenship, as required under Section 5(2) of Republic Act No. 9225,
which reads as follows:
Section 5. Civil and Political Rights and Liabilities.Those who retain or reacquire Philippine
citizenship under this Act shall enjoy full civil and political rights and be subject to all
attendant liabilities and responsibilities under existing laws of the Philippines and the
following conditions:
xxxx
(2) Those seeking elective public office in the Philippines shall meet the qualifications for
holding such public office as required by the Constitution and existing laws and, at the
time of the filing of the certificate of candidacy, make a personal and sworn
renunciation of any and all foreign citizenship before any public officer authorized to
administer an oath.
RULING: Contrary to the assertions made by petitioner, his oath of allegiance to the
Republic of the Philippines made before the Los Angeles PCG and his Certificate of
Candidacy do not substantially comply with the requirement of a personal and sworn
renunciation of foreign citizenship because these are distinct requirements to be
complied with for different purposes.
Section 3 of Republic Act No. 9225 requires that natural-born citizens of the Philippines,
who are already naturalized citizens of a foreign country, must take an oath of
allegiance to the Republic of the Philippines to reacquire or retain their Philippine
citizenship.
By the oath dictated in the afore-quoted provision, the Filipino swears allegiance to the
Philippines, but there is nothing therein on his renunciation of foreign citizenship. Precisely,
a situation might arise under Republic Act No. 9225 wherein said Filipino has dual
citizenship by also reacquiring or retaining his Philippine citizenship, despite his foreign
citizenship.
The afore-quoted oath of allegiance is substantially similar to the one contained in the

Certificate of Candidacy which must be executed by any person who wishes to run for
public office in Philippine elections.
Now, Section 5(2) of Republic Act No. 9225 specifically requires persons seeking elective
public office, who either retained their Philippine citizenship or those who reacquired it,
to make a personal and sworn renunciation of any and all foreign citizenship before a
public officer authorized to administer an oath simultaneous with or before the filing of
the certificate of candidacy.
Hence, Section 5(2) of Republic Act No. 9225 compels natural-born Filipinos, who have
been naturalized as citizens of a foreign country, but who reacquired or retained their
Philippine citizenship (1) to take the oath of allegiance under Section 3 of Republic Act
No. 9225, and (2) for those seeking elective public offices in the Philippines, to
additionally execute a personal and sworn renunciation of any and all foreign citizenship
before an authorized public officer prior or simultaneous to the filing of their certificates
of candidacy, to qualify as candidates in Philippine elections.
Clearly Section 5(2) of Republic Act No. 9225 (on the making of a personal and sworn
renunciation of any and all foreign citizenship) requires of the Filipinos availing 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).
MANZANO AND VALLES, MISAPPLICATION: Petitioner erroneously invokes the doctrine in
Valles and Mercado, wherein the filing by a person with dual citizenship of a certificate
of candidacy, containing an oath of allegiance, was already considered a renunciation
of foreign citizenship. The ruling of this Court in Valles and Mercado is not applicable to
the present case, which is now specially governed by Republic Act No. 9225,
promulgated on 29 August 2003.
The Court in the aforesaid cases sought to define the term "dual citizenship" vis--vis the
concept of "dual allegiance." At the time this Court decided the cases of Valles and
Mercado on 26 May 1999 and 9 August 2000, respectively, the more explicitly worded
requirements of Section 5(2) of Republic Act No. 9225 were not yet enacted by our
legislature.
DE GUZMAN V. DELA CRUZ
Petitioner De Guzman and private respondent Angelina DG. Dela Cruz were candidates
for vice-mayor of Guimba, Nueva Ecija in the May 14, 2007 elections. On April 3, 2007,
private respondent filed against petitioner a petition for disqualification docketed as SPA
No. 07-211, alleging that petitioner is not a citizen of the Philippines, but an immigrant
and resident of the United States of America.
In his answer, petitioner admitted that he was a naturalized American. However, on
January 25, 2006, he applied for dual citizenship under Republic Act No. 9225 (R.A. No.
9225), otherwise known as the Citizenship Retention and Re-Acquisition Act of 2003. Upon
approval of his application, he took his oath of allegiance to the Republic of the
Philippines on September 6, 2006. He argued that, having re-acquired Philippine
citizenship, he is entitled to exercise full civil and political rights.
R.A. No. 9225 was enacted to allow re-acquisition and retention of Philippine citizenship

for: 1) natural-born citizens who have lost their Philippine citizenship by reason of their
naturalization as citizens of a foreign country; and 2) natural-born citizens of the
Philippines who, after the effectivity of the law, become citizens of a foreign country. The
law provides that they are deemed to have re-acquired or retained their Philippine
citizenship upon taking the oath of allegiance.
Petitioner falls under the first category, being a natural-born citizen who lost his Philippine
citizenship upon his naturalization as an American citizen. In the instant case, there is no
question that petitioner re-acquired his Philippine citizenship after taking the oath of
allegiance on September 6, 2006. However, it must be emphasized that R.A. No. 9225
imposes an additional requirement on those who wish to seek elective public office, as
follows: a personal and sworn renunciation of any and all foreign citizenship before any
public officer authorized to administer an oath.
Breaking down the afore-quoted provision, for a natural born Filipino, who reacquired or
retained his Philippine citizenship under Republic Act No. 9225, to run for public office, he
must: (1) meet the qualifications for holding such public office as required by the
Constitution and existing laws; and (2) make a personal and sworn renunciation of any
and all foreign citizenships before any public officer authorized to administer an oath.
Further, in Jacot v. Dal and COMELEC, the Court ruled that a candidates oath of
allegiance to the Republic of the Philippines and his Certificate of Candidacy do not
substantially comply with the requirement of a personal and sworn renunciation of
foreign citizenship.
JAPZON V. COMELEC
Both petitioner Manuel B. Japzon (Japzon) and private respondent Jaime S. Ty (Ty) were
candidates for the Office of Mayor of the Municipality of General Macarthur, Eastern
Samar, in the local elections held on 14 May 2007.
On 15 June 2007, Japzon instituted SPA No. 07-568 by filing before the COMELEC a
Petition to disqualify and/or cancel Tys Certificate of Candidacy on the ground of
material misrepresentation. Japzon averred in his Petition that Ty was a former naturalborn Filipino, having been born on 9 October 1943 in what was then Pambujan Sur,
Hernani Eastern Samar (now the Municipality of General Macarthur, Easter Samar) to
spouses Ang Chim Ty (a Chinese) and Crisanta Aranas Sumiguin (a Filipino). Ty eventually
migrated to the United States of America (USA) and became a citizen thereof. Ty had
been residing in the USA for the last 25 years.
While Ty may have applied for the reacquisition of his Philippine citizenship, Ty continued
to make trips to the USA, the most recent of which was on 31 October 2006 lasting until 20
January 2007. Moreover, although Ty already took his Oath of Allegiance to the Republic
of the Philippines, he continued to comport himself as an American citizen as proven by
his travel records. He had also failed to renounce his foreign citizenship as required by
Republic Act No. 9225, otherwise known as the Citizenship Retention and Reacquisition
Act of 2003, or related laws.
In his Answer, Ty alleged, among others, that he executed on 19 March 2007 a duly
notarized Renunciation of Foreign Citizenship.
RULING: There is no dispute that Ty was a natural-born Filipino. He was born and raised in

the Municipality of General Macarthur, Eastern Samar, Philippines. However, he left to

work in the USA and eventually became an American citizen. On 2 October 2005, Ty
reacquired his Philippine citizenship by taking his Oath of Allegiance to the Republic of
the Philippines before Noemi T. Diaz, Vice Consul of the Philippine Consulate General in
Los Angeles, California, USA, in accordance with the provisions of Republic Act No. 9225.
At this point, Ty still held dual citizenship, i.e., American and Philippine. It was only on 19
March 2007 that Ty renounced his American citizenship before a notary public and,
resultantly, became a pure Philippine citizen again.
It bears to point out that Republic Act No. 9225 governs the manner in which a naturalborn Filipino may reacquire or retain his Philippine citizenship despite acquiring a foreign
citizenship, and provides for his rights and liabilities under such circumstances. A close
scrutiny of said statute would reveal that it does not at all touch on the matter of
residence of the natural-born Filipino taking advantage of its provisions. Republic Act No.
9225 imposes no residency requirement for the reacquisition or retention of Philippine
citizenship; nor does it mention any effect of such reacquisition or retention of Philippine
citizenship on the current residence of the concerned natural-born Filipino. Clearly,
Republic Act No. 9225 treats citizenship independently of residence. This is only logical
and consistent with the general intent of the law to allow for dual citizenship. Since a
natural-born Filipino may hold, at the same time, both Philippine and foreign citizenships,
he may establish residence either in the Philippines or in the foreign country of which he is
also a citizen.
For a natural born Filipino, who reacquired or retained his Philippine citizenship under
Republic Act No. 9225, to run for public office, he must: (1) meet the qualifications for
holding such public office as required by the Constitution and existing laws; and (2)
make a personal and sworn renunciation of any and all foreign citizenships before any
public officer authorized to administer an oath.
That Ty complied with the second requirement is beyond question. On 19 March 2007, he
personally executed a Renunciation of Foreign Citizenship before a notary public. By the
time he filed his Certificate of Candidacy for the Office of Mayor of the Municipality of
General Macarthur, Eastern Samar, on 28 March 2007, he had already effectively
renounced his American citizenship, keeping solely his Philippine citizenship.
The other requirement of Section 5(2) of Republic Act No. 9225 pertains to the
qualifications required by the Constitution and existing laws.
CORDORA v. COMELEC
Tambunting does not deny that he is born of a Filipino mother and an American father.
Neither does he deny that he underwent the process involved in INS Form I-130 (Petition
for Relative) because of his fathers citizenship. Tambunting claims that because of his
parents differing citizenships, he is both Filipino and American by birth. Cordora, on the
other hand, insists that Tambunting is a naturalized American citizen.
Tambunting possesses dual citizenship. Because of the circumstances of his birth, it was
no longer necessary for Tambunting to undergo the naturalization process to acquire
American citizenship. The process involved in INS Form I-130 only served to confirm the
American citizenship which Tambunting acquired at birth. The certification from the
Bureau of Immigration which Cordora presented contained two trips where Tambunting
claimed that he is an American. However, the same certification showed nine other trips

where Tambunting claimed that he is Filipino. Clearly, Tambunting possessed dual

citizenship prior to the filing of his certificate of candidacy before the 2001 elections. The
fact that Tambunting had dual citizenship did not disqualify him from running for public
office.
Requirements for dual citizens from birth who desire to run for public office
We have to consider the present case in consonance with our rulings in Mercado v.
Manzano, Valles v. COMELEC, and AASJS v. Datumanong. Mercado and Valles involve
similar operative facts as the present case. Manzano and Valles, like Tambunting,
possessed dual citizenship by the circumstances of their birth. Manzano was born to
Filipino parents in the United States which follows the doctrine of jus soli. Valles was born
to an Australian mother and a Filipino father in Australia. Our rulings in Manzano and
Valles stated that dual citizenship is different from dual allegiance both by cause and, for
those desiring to run for public office, by effect. Dual citizenship is involuntary and arises
when, as a 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. Thus, like any
other natural-born Filipino, it is enough for a person with dual citizenship who seeks public
office to file his certificate of candidacy and swear to the oath of allegiance contained
therein.
Dual allegiance, on the other hand, is brought about by the individuals active
participation in the naturalization process. AASJS states that, under R.A. No. 9225, a
Filipino who becomes a naturalized citizen of another country is allowed to retain his
Filipino citizenship by swearing to the supreme authority of the Republic of the Philippines.
The act of taking an oath of allegiance is an implicit renunciation of a naturalized
citizens foreign citizenship.
In Sections 2 and 3 of R.A. No. 9225, the framers were not concerned with dual citizenship
per se, but with the status of naturalized citizens who maintain their allegiance to their
countries of origin even after their naturalization. Section 5(3) of R.A. No. 9225 states that
naturalized citizens who reacquire Filipino citizenship and desire to run for elective public
office in the Philippines shall "meet the qualifications for holding such public office as
required by the Constitution and existing laws and, at the time of filing the certificate of
candidacy, 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. No. 9225. The twin requirements of swearing to
an Oath of Allegiance and executing a Renunciation of Foreign Citizenship served as the
bases for our recent rulings in Jacot v. Dal and COMELEC, Velasco v. COMELEC, and
Japzon v. COMELEC, all of which involve natural-born Filipinos who later became
naturalized citizens of another country and thereafter ran for elective office in the
Philippines. In the present case, Tambunting, a natural-born Filipino, did not subsequently
become a naturalized citizen of another country. Hence, the twin requirements in R.A.
No. 9225 do not apply to him.