ISSUE: effectively repudiated his American citizenship and anything which he

Whether or not a dual citizen is disqualified to hold public elective office
in the Philippines.
RULING:
The court ruled that the phrase "dual citizenship" in R.A. 7160 Sec. 40 (d)
and R.A. 7854 Sec. 20 must be understood as referring to dual allegiance.
Dual citizenship is different from dual allegiance. The former arises when,
as a result of the application of the different laws of two or more states,
a person is simultaneously considered a national by the said states. Dual
allegiance on the other hand, refers to a 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 a result of an
individual's volition. Article IV Sec. 5 of the Constitution provides "Dual
allegiance of citizens is inimical to the national interest and shall be dealt
with by law."
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.
may have said before as a dual citizen.
On the other hand, private respondent’s 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. In Yu v. Defensor-
Santiago, the court sustained the denial of entry into the country of
petitioner on the ground that, after taking his oath as a naturalized
citizen, he applied for the renewal of his Portuguese passport and
declared in commercial documents executed abroad that he was a
Portuguese national. A similar sanction can be taken against any one
who, in electing Philippine citizenship, renounces his foreign nationality,
but subsequently does some act constituting renunciation of his
Philippine citizenship.

The court ruled that the filing of certificate of candidacy of respondent

sufficed to renounce his American citizenship, effectively removing any
disqualification he might have as a dual citizen. 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,