Loss of Citizenship

Yu v. Defensor Santiago

– Portuguese passport – Yu’s act of applying for a Portuguese passport despite his naturalization as a Philippine citizen and his act of declaring his 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 one’s 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;


– 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 Labo’s 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 Osmeña; American citizenship – Aznar failed to present direct proof that Osmeña
had lost his Filipino citizenship by any of the modes provided by law; The fact the Osmeña was both a Filipino and an American does not mean that he is not still a Filipino;