ND Mercado v. Manzano, G.R. No. 135083, May 26, 1999)

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G.R. No. 135083: Mercado v Manzano Case Digest

Article · May 1999

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Case Brief Bjørn Henrik Panis

G.R. No. 135083


May 26, 1999
ERNESTO S. MERCADO, PETITIONER, VS. EDUARDO BARRIOS
MANZANO AND THE COMMISSION ON ELECTIONS,
RESPONDENTS.

FACTS: The petitioner, Eduardo Barrios Manzano, was born in the United States, San Francisco,
California on September 14, 1955 to a Filipino father and mother. He was granted a dual citizenship
upon his birth due to jus solis of US laws and jus sanguinis of the Philippine laws. By the age of six
years old, he arrived in the Philippines using an American passport and was later registered as an
alien and upon reaching the age of majority, he registered as a voter and exercised his right to vote
three times clearly and officially renunciating his American citizenship applicable to both laws.

Consequently, he became a winning candidate for vice mayor of the City of Makati in the May 11,
1998 elections however, prior to its announcement, respondent filed a petition of disqualification
against Manzano.

ISSUE: W/N Eduardo Barrios Manzano is eligible for the office he seeks to be elected while
withholding the fact that he may have a dual citizenship with the Philippines and the United States
of America.

RULING: Eduardo Barrios Manzano is eligible for the position of vice-mayor of Makati City in the
May 11, 1998, elections.

HELD: Manzano only have Filipino as his citizenship as noting by the indisputable fact that
he registered as a voter upon reaching the age of majority and exercised his right to suffrage in
1992, 1995 and 1998 thereby renunciating his US Citizenship under the American Law. Likewise,
under the Philippine Law, he no longer has U.S. Citizenship.

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