4/29/2020 E-Library - Information At Your Fingertips: Printer Friendly it is a renunciation manifested by direct and appropriate language, as distinguished from that which is inferred from conduct.[36] A clear and vivid example, taken from jurisprudence, of what “express renunction” is not transpired in Aznar v. Comelec[37] where the Court ruled that the mere fact that respondent Osmena was a holder of a certificate stating that he is an American did not mean that he is no longer a Filipino, and that an application for an alien certificate of registration did not amount to a renunciation of his Philippine citizenship. In the present case, other than the use of his US passport in two trips to and from the United States, the record does not bear out any indication, supported by evidence, of Arnado’s intention to re-acquire US citizenship. To my mind, in the absence of clear and affirmative acts of re-acquiring US citizenship either by naturalization or by express acts (such as the re-establishment of permanent residency in the United States), Arnado’s use of his US passport cannot but be considered an isolated act that did not undo his renunciation of his US citizenship. What he might in fact have done was to violate American law on the use of passports, but this is a matter irrelevant to the present case. Thus, Arnado remains to be a “pure” Filipino citizen and the loss of his Philippine citizenship cannot be presumed or inferred from his isolated act of using his US passport for travel purposes. Arnado did not violate his oath of renunciation; at any rate, all doubts should be resolved in favor of Arnado’s eligibility considering that he received the popular mandate of the people of Kauswagan, Lanao del Norte as their duly elected mayor I completely agree with the ponencia that the Oath of Renunciation is not an empty or formal ceremony that can be perfunctorily professed at any given day, only to be disregarded on the next. As a mandatory requirement under Section 5 (2) of RA 9225, it allows former natural-born Filipino citizens who were deemed to have lost their Philippine citizenship by reason of naturalization as citizens of a foreign country to enjoy full civil and political rights, foremost among them, the privilege to run for public office. I disagree however, with the conclusion that Arnado effectively negated his Oath of Renunciation when he used his US passport for travel to the United States. To reiterate if only for emphasis, Arnado sufficiently justified the use of his US passport despite his renunciation of his US citizenship; when he travelled on April 14, 2009, June 25, 2009 and July 29, 2009, he had no Philippine passport that he could have used to travel to the United States to attend to the business and other affairs that he was leaving. If at all, he could be faulted for using his US passport by the time he returned to the Philippines on November 24, 2009 because at that time, he had presumably received his Philippine passport. However, given the circumstances explained above and that he consistently used his Philippine passport for travel after November 24, 2009, the true character of his use of his US passport stands out and cannot but be an isolated and convenient act that did not negate his Oath of Renunciation. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/55820 44/49