Loss of Citizenship

Yu v. Defensor Santiago
Portuguese passport Yus act of applying for a Portuguese passport despite his naturalization as a Philippine citizen and his act of declaring hi s nationality as Portuguese in commercial documents, constitute an EXPRESS renunciation of his Philippine citizenship acquired through naturalization; Philippine citizenship is not a commodity or ware to be displayed when required and suppressed when convenient

Frivaldo v. COMELEC
governor-elect of Sorsogon; American citizenship; repatriation Loss of naturalized Philippine citizenship did not and could not have the effect of automatic restoration of ones Philippine citizenship; mere filing of certificate of candidacy wherein Frivaldo claimed that he is a natural born citizen is not a sufficient act of repatriation; repatriation requires an express and unequivocal act;

Labo v. COMELEC
mayor of Baguio City; Australian citizenship; bigamous marriage Res judicata does not apply to questions of citizenship;

Modes by which Philippine citizenship may be lost:

a. naturalization in a foreign country b. express renunciation of citizenship c. subscribing to an oath of allegiance to support the Constitution or laws of a foreign country; annulment of Labos Australian citizenship as a result of finding that his marriage to an Australian national was bigamous did not automatically restore his Philippine citizenship; Philippine citizenship may be acquired by direct act of Congress; by naturalization or by repatriation.

Aznar v. COMELEC
disqualification of Osmea; American citizenship Aznar failed to present direct proof that Osmea had lost his Filipino citizenship by any of the modes provided by law; The fact the Osmea was both a Filipino and an American does not mean that he is not still a Filipino;

Citizens by election
Co v. HRET
- representative; 2nd District of Samar; election of citizenship The exercise of the right to suffrage and the participation in election exercises constitute a positive act of election of Philippine citizenship; Any election of Philippine citizenship on the part of Jose Ong would not only have been superfluous but would also have resulted in absurdity considering that it was the law itself that had already elected Philippine citizenship for him.

In re: Ching
permission to take the lawyers oath; Ching elected Filipino citizenship beyond the required upon reaching the age of majority If the citizenship of a person was subject to challenge under the old charter, it remains subject to challenge under the new charter even if the judicial challenge had not been commenced before the effectivity of the new Constitution; CA 625 and the 1935 Constitution did not prescribe a time within which the election of Philippine citizenship should be made; reasonable time; upon reaching the age of majority it was clearly beyond by any reasonable yardstick, the able period to exercise the privilege.