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LABO vs.

COMELEC Case Digest


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 a 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
LABO VS. COMELEC, digested
FACTS: Herein petitioner, claiming for recognition as a Philippine citizen is a mayor-elect
who, through his marriage with an Australian national, was naturalized and took an oath of
allegiance as an Australian citizen. Said marriage was found to be bigamous and therefore
was annulled. Petitioner claims that his naturalization made him only a dual national and did
not divest him of his Philippine citizenship.
ISSUE: Whether or not petitioner was divested of his Philippine citizenship.
HELD: Yes, because Commonwealth Act No. 63 clearly stated that Philippine citizenship may
be lost through naturalization in a foreign country; express renunciation of citizenship; and
by oath of allegiance to a foreign country, all of which are applicable to the petitioner.