Antonio Bengzon III vs.

House of
Representative Electoral Tribunal
G.R. No. 142840, May 7, 2001

FACTS: The citizenship of respondent Cruz is at issue in this case, in view of the constitutional
requirement that “no person shall be a Member of the House of Representatives unless he is a
natural-born citizen.”

Cruz was a natural-born citizen of the Philippines. He was born in Tarlac in 1960 of Filipino
parents. In 1985, however, Cruz enlisted in the US Marine Corps and without the consent of the
Republic of the Philippines, took an oath of allegiance to the USA. As a Consequence, he lost
his Filipino citizenship for under CA No. 63 [(An Act Providing for the Ways in Which Philippine
Citizenship May Be Lost or Reacquired (1936)] section 1(4), a Filipino citizen may lose his
citizenship by, among other, “rendering service to or accepting commission in the armed forces
of a foreign country.”

Whatever doubt that remained regarding his loss of Philippine citizenship was erased by his
naturalization as a U.S. citizen in 1990, in connection with his service in the U.S. Marine Corps.

In 1994, Cruz reacquired his Philippine citizenship through repatriation under RA 2630 [(An Act
Providing for Reacquisition of Philippine Citizenship by Persons Who Lost Such Citizenship by
Rendering Service To, or Accepting Commission In, the Armed Forces of the United States
(1960)]. He ran for and was elected as the Representative of the 2nd District of Pangasinan in
the 1998 elections. He won over petitioner Bengson who was then running for reelection.

Subsequently, petitioner filed a case for Quo Warranto Ad Cautelam with respondent HRET
claiming that Cruz was not qualified to become a member of the HOR since he is not a
natural-born citizen as required under Article VI, section 6 of the Constitution.

HRET rendered its decision dismissing the petition for quo warranto and declaring Cruz the duly
elected Representative in the said election.

ISSUE: WON Cruz, a natural-born Filipino who became an American citizen, can still be
considered a natural-born Filipino upon his reacquisition of Philippine citizenship.

HELD: Yes. Petition dismissed

Filipino citizens who have lost their citizenship may however reacquire the same in the manner
provided by law. C.A. No. 63 enumerates the 3 modes by which Philippine citizenship may be
reacquired by a former citizen:
 1. by naturalization,
2. by repatriation, and
3. by direct act of Congress.

Repatriation may be had under various statutes by those who lost their citizenship due to:

1. desertion of the armed forces;

2. services in the armed forces of the allied forces in World War II;
3. service in the Armed Forces of the United States at any other time,
4. marriage of a Filipino woman to an alien; and
5. political economic necessity

Repatriation results in the recovery of the original nationality This means that a naturalized
Filipino who lost his citizenship will be restored to his prior status as a naturalized Filipino
citizen. On the other hand, if he was originally a natural-born citizen before he lost his Philippine
citizenship, he will be restored to his former status as a natural-born Filipino.

R.A. No. 2630 provides:

Sec 1. Any person who had lost his Philippine citizenship by rendering service to, or
accepting commission in, the Armed Forces of the United States, or after separation
from the Armed Forces of the United States, acquired United States citizenship, may
reacquire Philippine citizenship by taking an oath of allegiance to the Republic of the
Philippines and registering the same with Local Civil Registry in the place where he
resides or last resided in the Philippines. The said oath of allegiance shall contain a
renunciation of any other citizenship.

Having thus taken the required oath of allegiance to the Republic and having registered the
same in the Civil Registry of Magantarem, Pangasinan in accordance with the aforecited
provision, Cruz is deemed to have recovered his original status as a natural-born citizen, a
status which he acquired at birth as the son of a Filipino father. It bears stressing that the act of
repatriation allows him to recover, or return to, his original status before he lost his Philippine
citizenship.

DOCTRINES

Constitutional Law; Citizenship;

- There are two ways of acquiring citizenship: (1) by birth and (2) by naturalization; A
person who at the time of his birth is a citizen of a particular country, is a natural-born
citizen thereof

Repatriation results in the recovery of the original nationality.

- Repatriation results in the recovery of the original nationality. This means that a
 naturalized Filipino who lost his citizenship will be restored to his prior status as a
naturalized Filipino citizen. On the other hand, if he was originally a natural-born
citizen before he lost his Philippine citizenship, he will be restored to his former status
as a natural-born Filipino

A citizen who is not a naturalized Filipino, i.e., did not have to undergo the process of
naturalization to obtain Philippine citizenship, necessarily is a natural-born Filipino; As
respondent Cruz was not required by law to go through naturalization proceedings in
order to reacquire his citizenship, he is perforce a natural-born Filipino.
- Consequently, only naturalized Filipinos are considered not natural-born citizens. It is
apparent from the enumeration of who are citizens under the present Constitution that
there are only two classes of citizens: (1) those who are natural-born and (2) those
who are naturalized in accordance with law.
- The absence in said enumeration of a separate category for persons who, after losing
Philippine citizenship, subsequently reacquire it. The reason therefore is clear:
they would either be natural-born or naturalized depending on the reasons for
the loss of their citizenship and the mode prescribed by the applicable law for
the reacquisition thereof.

Mary Grace Natividad Poe-Llamanzares vs.

Commission on Election
G.R. No. 221697-221700, March 8, 2016

Facts: Petitioner Mary Grace Natividad S. Poe-Llamanzares was found abandoned as a

newborn infant in the Parish Church of Jaro, Iloilo on Sept. 3, 1968. After passing the parental
care and custody over petitioner by Edgardo Militar to Emiliano Militar and his wife, she has
been reported and registered as a foundling and issued a Foundling Certificate and Certificate
of Live Birth, thus was given the name, Mary Grace Natividad Contreras Militar.

When the petitioner reached the age of five (5), celebrity spouses Ronal Allan Kelley (aka
Fernando Poe, Jr) and Jesusa Sonora Poe (aka Susan Roces) filed a petition for her adoption.
The trial court granted their petition and ordered that her name be changed to Mary Grace
Natividad Sonora Poe.

Petitioner registered as a voter in San Juan City at the age of 18 in 1986; in 1988, she applied
and was issued Philippine Passport by the DFA; in 1993 and 1998, she renewed her passport.

She left for the United States (U.S.) in 1988 to continue her studies after enrolling and pursuing
a degree in Development Studies at the University of the Philippines. She graduated in 1991
from Boston College where she earned her Bachelor of Arts degree in Political Studies.
She married Teodoro Misael Daniel V. Llamanzares, a citizen of both the Philippines and the
U.S., in San Juan City and decided to flew back to the U.S. after their wedding. She gave birth
to her eldest child while in the U.S.; and her two daughters in the Philippines.

She became a naturalized American citizen in 2001. She came back to the Philippines to
support her father’s candidacy for president in the May 2004 elections and gave birth to her
youngest daughter. They then returned to the U.S. in 2004 but after a few months, she rushed
back to the Philippines to attend to her ailing father. After her father’s death, the petitioner and
her husband decided to move and reside permanently in the Philippines in 2005 and
immediately secured a TIN, then her children followed suit; acquired property where she and
her children resided.

In 2006, She took her Oath of Allegiance to the Republic of the Philippines pursuant to RA No.
9225 or the Citizenship retention and Re-acquisition Act of 2003; she filed a sworn petition to
reacquire Philippine citizenship together with petitions for derivative citizenship on behalf of her
three children which was granted. She registered as a voter; secured Philippine passport;
appointed and took her oath as Chairperson of the MTRCB after executing an affidavit of
Renunciation of American citizenship before the Vice Consul of the USA and was issued a
Certificate of Loss of Nationality of the USA in 2011.

In 2012, she filed with the COMELEC her Certificate of Candidacy (COC) for Senator for the
2013 Elections wherein she answered “6 years and 6 months” to the question “Period of
residence in the Philippines before May 13, 2013.” Petitioner obtained the highest number of
votes and was proclaimed Senator on 16 May 2013.

On 15 October 2015, petitioner filed her COC for the Presidency for the May 2016 Elections. In
her COC, the petitioner declared that she is a natural-born citizen and that her residence in the
Philippines up to the day before 9 May 2016 would be ten (10) years and eleven (11) months
counted from 24 May 2005. The petitioner attached to her COC an “Affidavit Affirming
Renunciation of U.S.A. Citizenship” subscribed and sworn to before a notary public in Quezon
City on 14 October 2015.

Petitions were filed before the COMELEC to deny or cancel her candidacy on the ground
particularly, among others, that she cannot be considered a natural-born Filipino citizen since
she cannot prove that her biological parents or either of them were Filipinos. The COMELEC en
banc cancelled her candidacy on the ground that she was in want of citizenship and residence
requirements, and that she committed material misrepresentations in her COC.

On certiorari, the Supreme Court reversed the ruling and held (9-6 votes) that Poe is qualified
as a candidate for Presidency. Three justices, however, abstained to vote on the natural-born
citizenship issue.

Issue: Whether or not Mary Grace Natividad S. Poe-Llamanzares is a natural-born Filipino

citizen.
Held: Yes. Mary Grace Natividad S. Poe-Llamanzares may be considered a natural-born
Filipino.

It ruled that a foundling is a natural-born citizen of the Philippines as there is no restrictive

language which would definitely exclude foundlings as they are already impliedly so recognized.

There are also no provisions in the Constitution with intent or language permitting discrimination
against foundlings as the three Constitutions guarantee the basic right to equal protection of the
laws.

Foundlings are citizens under international law as this is supported by some treaties, adhering
to the customary rule to presume foundlings as having been born of the country in which the
foundling is found.

DOCTRINES

Cancellation of Certificate of Candidacy; Misrepresentation; If a candidate cannot be

disqualified without a prior finding that he or she is suffering from a disqualification
“provided by law or the Constitution,” neither can the certificate of candidacy (CoC) be
canceled or denied due course on grounds of false representations regarding his or
her qualifications, without a prior authoritative finding that he or she is not qualified,
such prior authority being the necessary measure by which the falsity of the
representation can be found
- The only exception that can be conceded are self-evident facts of unquestioned or
unquestionable veracity and judicial confessions. Such are, anyway, bases equivalent
to prior decisions against which the falsity of representation can be determined.
Poe-Llamanzares vs. Commission on Elections, 786 SCRA 1, G.R. No. 221697, G.R.
Nos. 221698-700 March 8, 2016

Citizenship; Burden of Proof; The burden of proof was on private respondents to show
that petitioner is not a Filipino citizen.
- The private respondents should have shown that both of petitioner’s parents were
aliens. Her admission that she is a foundling did not shift the burden to her because
such status did not exclude the possibility that her parents were Filipinos, especially as
in this case where there is a high probability, if not certainty, that her parents are
Filipinos.

Foundlings; Presumptions; That a person with typical Filipino features is abandoned in

Catholic Church in a municipality where the population of the Philippines is
overwhelmingly Filipinos such that there would be more than a ninety-nine percent
(99%) chance that a child born in the province would be a Filipino, would indicate more
than ample probability if not statistical certainty, that petitioner’s parents are Filipinos.
As a matter of law, foundlings are as a class, natural-born citizens.
- While the 1935 Constitution’s enumeration is silent as to foundlings, there is no
restrictive language which would definitely exclude foundlings either

Domestic laws on adoption also support the principle that foundlings are Filipinos
- These laws do not provide that adoption confers citizenship upon the adoptee. Rather,
the adoptee must be a Filipino in the first place to be adopted. The most basic of such
laws is Article 15 of the Civil Code

Foundlings are likewise citizens under international law.

- Foundlings are likewise citizens under international law. Under the 1987 Constitution,
an international law can become part of the sphere of domestic law either by
transformation or incorporation.

It is the fact of residence, not a statement in a certificate of candidacy (CoC) which

ought to be decisive in determining whether or not an individual has satisfied the
constitution’s residency qualification requirement.

A person can have but one (1) domicile at a time. Once established, the domicile
remains until a new one is acquired.
- A person’s domicile of origin is the domicile of his parents. It is not easily lost and
continues even if one has lived and maintained residences in different places.
Absence from the domicile to pursue a profession or business, to study or to do other
things of a temporary or semi-permanent nature, and even travels abroad, does not
constitute loss of residence. In contrast, immigration to a foreign country with the
intention to live there permanently constitutes an abandonment of domicile in the
Philippines. In order to qualify to run for public office in the Philippines, an immigrant to
a foreign country must waive such status as manifested by some act or acts
independent of and done prior to the filing of the certificate of candidacy. A person can
have but one domicile at a time. Once established, the domicile remains until a new
one is acquired. In order to acquire a domicile by choice, there must concur:
(a) physical presence in the new place,
(b) an intention to remain there (animus manendi), and
(c) an intention to abandon the former domicile (animus non revertendi).
Without clear and positive proof of the concurrence of these requirements, the
domicile of origin continues.

Domicile; View that petitioner registered as a voter on 31 August 2006. This speaks
loudly of the intent to establish a domicile in the country

Citizenship; Foundlings; Passports; View that if the State considers foundlings to be

anything else but its citizens (stateless persons, for example), it would not have given
them passports.
- When the claim to Philippine citizenship is doubtful, only a “travel document” is issued.
A travel document, in lieu of a passport, is issued to stateless persons who are
likewise permanent residents, or refugees granted such status or asylum in the
Philippines. If the State considers foundlings to be anything else but its citizens
(stateless persons, for example), it would not have given them passports.
 The concept of natural-born citizenship, originally meant to distinguish those who are
“natural-born” from those who are “foreign-born” in jus soli jurisdictions, cannot be
used to justify the denial of citizenship status to foundlings because of their inability to
prove a certain blood relationship.

Ernesto Mercado vs. Eduardo Barrios Manzano

and COMELEC
G.R. No. 135083, May 26, 1996

FACTS: Petitioner Ernesto S. Mercado (Mercado) and private respondent Eduardo B. Manzano
(Manzano) were candidates for vice mayor of the City of Makati in the May 1998 elections.
Respondent won. A certain Ernesto Mamaril (Mamaril) filed a petition for disqualification against
Manzano on the ground that he was not a citizen of the Philippines but of the United States.
Commission on Election (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 40(d) of the Local Government Code, persons with dual citizenship are
disqualified from running for any elective position.

According to COMELEC, respondent admitted that he is registered as a foreigner with the

Bureau of Immigration and alleged that he is a Filipino citizen because he was born in 1955 of a
Filipino father and a Filipino mother. He was born in the United States, San Francisco,
California, September 14, 1955, and is considered in American citizen under US Laws. But
notwithstanding his registration as an American citizen, he did not lose his Filipino citizenship.
Thus, he is considered a dual citizen. And as a law, persons with dual citizenship are
disqualified from running for any elective position.

Private respondent filed a motion for reconsideration. The motion remained pending even until
after the election held on May 11, 1998. The petitioner sought to intervene in the case for
disqualification. Petitioner's motion was opposed by private respondent. The motion was not
resolved. Instead, on August 31, 1998, the COMELEC en banc rendered its resolution in favor
of respondent Eduardo Barrios Manzano was born in San Francisco, California, U.S.A. He
acquired US citizenship by operation of the United States Constitution and laws under the
principle of jus soli. He was also a natural born Filipino citizen by operation of the 1935
Philippine Constitution, as his father and mother were Filipinos at the time of his birth.

Petitioner contends that COMELEC en banc ERRED in holding that:

A. Under Philippine law, Manzano was no longer a U.S. citizen when he:
1. He renounced his U.S. citizenship when he attained the age of majority when he was
already 37 years old; and,
 2. He renounced his U.S. citizenship when he (merely) registered himself as a voter and
voted in the elections of 1992, 1995 and 1998.
B. Manzano is qualified to run for and or hold the elective office of Vice-Mayor of the City of
Makati;
C. At the time of the May 11, 1998 elections, the resolution of the Second Division adopted on 7
May 1998 was not yet final so that, effectively, petitioner may not be declared the winner even
assuming that Manzano is disqualified to run for and hold the elective office of Vice-Mayor of the
City of Makati.

Hence, this petition for certiorari.

ISSUE: Whether or not respondent Manzano is a dual citizen and cannot run for public office.

HELD

To begin with, dual citizenship is different from dual allegiance.

Dual citizenship - 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 latter’s 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 individual’s volition.

The phrase “dual citizenship” in the Local Government Code 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
would 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.

By electing Philippine citizenship, such candidates at the same time forswear allegiance to the
other country of which they are also citizens and thereby terminate their status as dual citizens.
It may be that, from the point of view of the foreign state and of its laws, such an individual has
not effectively renounced his foreign citizenship. That is of no moment. The COMELEC en
banc’s ruling was that Manzano’s act of registering himself as a voter was an effective
renunciation of his American citizenship. This ruling is in line with the US Immigration and
Nationality Act wherein it is provided that “a person who is a national of the United States,
whether by birth or naturalization, shall lose his nationality by: (e) Voting in a political election in
a foreign state or participating in an election or plebiscite to determine the sovereignty over
foreign territory.” But this provision was declared unconstitutional by the US Supreme Court.
Nevertheless, our SC held that by filing a certificate of candidacy when he ran for his present
post, the private respondent elected Philippine citizenship and in effect renounced his American
citizenship.

To recapitulate, 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 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, we
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 anyone who, in electing Philippine citizenship, renounces
his foreign nationality, but subsequently does some act constituting renunciation of his Philippine
citizenship.

DOCTRINES
 Casan Macode Maquiling vs. COMELEC
G.R. No. 195649, April 16, 2013

FACTS: Rommel Arnado y Cagoco was a natural born Filipino citizen, who underwent
naturalization as a citizen of the United States of America. Arnado applied for repatriation before
the Consulate General of the Philippines in San Francisco, USA and took the Oath of Allegiance
to the Republic of the Philippines by virtue of RA 9225. By taking the Oath of Allegiance to the
Republic, Arnado re-acquired his Philippine citizenship. After reacquiring his Philippine
citizenship, Arnado renounced his American citizenship by executing an Affidavit of
Renunciation, thus completing the requirements for eligibility to run for public office.

Afterwards, Arnado ran for the position of municipal mayor in Kauswagan, Lanao del Norte.
Linog C. Balua, another mayoralty candidate, filed a petition to disqualify Arnado contending
that he is a foreigner and not a resident of the area.

He indicated that Arnado has been using his US Passport in entering and departing the
Philippines. Arnado garnered the highest number of votes. Meanwhile, Casan Macode
Maquiling, another candidate for mayoralty who garnered the second number of highest votes,
intervened in the case. Consequently, he claimed that the cancellation of Arnado’s candidacy
and the nullification of his proclamation, Maquiling, as the legitimate candidate who obtained the
highest number of lawful votes, should be proclaimed as the winner.

ISSUE: Will rnado’s continued use of US Passport constitute his loss of Philippine citizenship?

RULING: The use of foreign passport after renouncing one’s foreign citizenship is a positive and
voluntary act of representation as to one’s nationality and citizenship; it does not divest Filipino
citizenship regained by repatriation but it recants the Oath of Renunciation required to qualify
one to run for an elective position.

Between 03 April 2009, the date he renounced his foreign citizenship, and 30 November 2009,
the date he filed his COC, he used his US passport four times, actions that run counter to the
affidavit of renunciation he had earlier executed. While the act of using a foreign passport is not
one of the acts enumerated in Commonwealth Act No. 63 constituting renunciation and loss of
Philippine citizenship, it is nevertheless an act which repudiates the very oath of renunciation he
took. Such an act of using a foreign passport does not divest Arnado of his Filipino citizenship,
which he acquired by repatriation.

However, by representing himself as an American citizen, Arnado voluntarily and effectively

reverted to his earlier status as a dual citizen. By the time he filed his certificate of candidacy on
30 November 2009, Arnado was a dual citizen enjoying the rights and privileges of Filipino and
American citizenship. He was qualified to vote, but by the express disqualification under Section
40(d) of the Local Government Code, he was not qualified to run for a local elective position.

DOCTRINES

Rommel Arnado vs. COMELEC

G.R. No. 210164, August 18, 2015

FACTS:
Petitioner Arnado is a natural-born Filipino citizen who lost his Philippine citizenship after he
was naturalized as a US citizen.

Subsequently, and in preparation for his plans to run for public office in the Philippines, Arnado
applied for repatriation under RA 9225 before the Consul in San Francisco. He took the Oath of
Allegiance and executed an Affidavit of Renunciation of his foreign citizenship.

He then filed his 2009 COC for the mayoralty post of Lanao del Norte for the 2010 elections.
However, his co-candidate filed a petition to disqualify on the ground that he continued to use
his US passport for entry to and exit from the Philippines after executing his Affidavit of
Renunciation.

While the petition for disqualification was pending, the 2010 elections proceeded, wherein
Arnado garnered the highest votes and was proclaimed winner.

COMELEC 1st Division: Nullified proclamation and applied rule on succession.

Maquiling, another co-candidate who garnered 2nd highest votes, contested the application of
the rule on succession.

ISSUE:
Whether or not Arnado was correctly disqualified from running for public office by virtue of his
subsequent use of US passport, which effectively disavowed or recalled his 2009 Affidavit of
Renunciation.

RULING:
Yes, Arnado failed to comply with the 2nd requisite because as held in Maquiling, his 2009
Affidavit of Renunciation was deemed withdrawn when he used his US passport after executing
said affidavit. Since then up to the time he filed his COC in 2012, Arnado had not cured the
defect in his qualification.
Arnado had not yet satisfied the twin requirements of Section 5(2) of RA 9225 at the time he
filed his COC for the May 13, 2013 elections.

Under 4(d) of the LGC, a person with “dual citizenship” is disqualified from running for any
elective local position. This refers to dual allegiance. Consequently, congress enacted RA 9225
allowing natural-born citizens who have lost their Philippine citizenship by reason of
naturalization abroad to reacquire their Philippine citizenship and enjoy full civil and political
rights.

Hence, they may now run for public office provided they:

Meet the qualifications for holding such public office, and

Make a personal and sworn renunciation of any and all foreign citizenships before any public
officer authorized to administer an oath, prior to or at the time of filing their COC.

DOCTRINES

Juan G. Frivaldo vs. Commission on Elections

G.R. Nos. 120295 and 123755, June 28, 1996

DOCTRINES

Mateo Caasi vs. Court of Appeals

G.R. No. 88831 and 94508 November 8, 1990
Imelda Romualdez-Marcos vs. Commission on
Elections
G.R. No. 119976 September 18, 1995

DOCTRINES

Mo Ya Lim Yao v. Commissioner of Immigration

G.R. No. L-21289 October 4, 1971

DOCTRINES

Aniceto G. Saludo, Jr. vs. American Express

International
G.R. No. 159507, April 19, 2006;

DOCTRINES