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

May 26, 1999]

FACTS:

During the May 11, 1998 elections, Ernesto Mercado and Eduardo Manzano both ran for
the position of Vice-Mayor of Makati.

Manzano received the highest number of votes but his proclamation was put on hold
due to a disqualification petition filed by Mercado. Mercado alleged that Manzano,
despite being proclaimed as a winner, was not a Filipino citizen but a citizen of the
United States.

It was evident from the facts that Manzano held dual citizenship, being both a Filipino
and a US citizen.

The Commission on Elections (COMELEC) initially disqualified Manzano from holding

the elective position. However, the COMELEC en banc later reversed this decision,
stating that Manzano had renounced his US citizenship upon reaching the age of
majority and registering as a voter in the 1992, 1995, and 1998 elections.

Manzano was eventually proclaimed as the Vice-Mayor of Makati City on August 31,
1998.

This led to the filing of the present petition.

ISSUE:

Whether a dual citizen is disqualified from holding public elective office in the
Philippines.

RULING:

The court clarified that the term "dual citizenship" as mentioned in R.A. 7160 Sec. 40 (d)
and R.A. 7854 Sec. 20 pertains to dual allegiance, not simply holding citizenship in two
countries. Dual citizenship arises when a person is considered a national by multiple
states due to conflicting laws. On the other hand, dual allegiance involves owing loyalty
to two or more states simultaneously through a positive act.
The Constitution deems dual allegiance detrimental to national interest and subjects it
to legal action. However, individuals with mere dual citizenship, as opposed to dual
allegiance, do not fall under this disqualification.

For candidates with dual citizenship, they can elect Philippine citizenship upon filing
their certificates of candidacy, thereby terminating their dual citizenship status. This act
constitutes a renunciation of allegiance to their other country of citizenship, as
recognized by Philippine law.

The court emphasized that the validity of such renunciation lies within the jurisdiction of
Philippine courts and is not subject to interference by foreign laws.

In Manzano's case, his filing of the certificate of candidacy declaring his Filipino
citizenship effectively renounced his American citizenship under Philippine law. His
long-standing ties and activities in the Philippines further solidified his election of
Philippine citizenship.

The court dismissed the petition for lack of merit, affirming Manzano's eligibility to hold
public office despite his previous dual citizenship status.