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ANTONIO BENGSON III v. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL

FACTS:

Respondent Teodoro C. Cruz was a natural-born citizen of the Philippines, born to Filipino parents in 1960. However, in 1985, he enlisted in the United States Marine Corps without the consent of the Republic of the Philippines and took an oath of allegiance to the United States. As a result, he lost his Filipino citizenship under Commonwealth Act No. 63 as he rendered service to a foreign country. He further acquired US citizenship through naturalization in 1990. In 1994, respondent Cruz reacquired his Philippine citizenship through repatriation under Republic Act No. 2630. He then ran for and was elected as the Representative of the Second District of Pangasinan in the 1998 elections. Petitioner Antonio Bengson III filed a quo warranto case with the House of Representatives Electoral Tribunal (HRET) challenging respondent Cruz's qualifications as a natural-born citizen. The HRET dismissed the petition and declared respondent Cruz as the duly elected representative. Petitioner filed a petition for certiorari assailing the HRET's decision, arguing that respondent Cruz is no longer a natural-born citizen due to his loss and renunciation of Philippine citizenship.

ISSUES:

  1. Whether respondent Teodoro C. Cruz can still be considered a natural-born Filipino upon his reacquisition of Philippine citizenship.

  2. Whether respondent Cruz validly acquired his Philippine citizenship.

  3. Whether respondent Cruz's reacquisition of Philippine citizenship can restore his natural-born status.

RULING:

  1. The Supreme Court ruled in favor of respondent Teodoro C. Cruz.

PRINCIPLES:

  • Under the 1935 Constitution, a Filipino citizen may lose his citizenship by rendering service to or accepting commission in the armed forces of a foreign country without the consent of the Republic of the Philippines.

  • The loss of Philippine citizenship can be remedied through repatriation.

  • The 1987 Constitution defines natural-born citizens as those who are citizens of the Philippines from birth without having to perform any act to acquire or perfect their Philippine citizenship.

  • Naturalized citizens are those who have become Filipino citizens through the process of naturalization.