4/29/2020 E-Library - Information At Your Fingertips: Printer Friendly could have used to travel to the United States to attend to the winding up of his business and other affairs in America. A travel document issued by the proper Philippine government agency (e.g., a Philippine consulate office in the US) would not suffice because travel documents could not be used; they are issued only in critical instances, as determined by the consular officer, and allow the bearer only a direct, one-way trip to the Philippines.[35] Although Arnado received his Philippine passport by the time he returned to the Philippines on November 24, 2009, he could not use this without risk of complications with the US immigration authorities for using a travel document different from what he used in his entry into the US on July 29, 2009. Plain practicality then demanded that the travel document that he used to enter the US on July 29, 2009 be the same travel document he should use in leaving the country on November 24, 2009. Given these circumstances, Arnado’s use of his US passport in travelling back to the Philippines on November 24, 2009 was an isolated act that could not, by itself, be an express renunciation of the Philippine citizenship he adopted as his sole citizenship under RA 9225. Arnado’s use of his US passport was not an express renunciation of his Philippine citizenship under Section 1 of CA 63. I disagree with the ponencia’s view that by using his US passport and representing himself as an American citizen, Arnado effectively reverted to the status of a dual citizen. Interestingly, the ponencia failed to cite any law or controlling jurisprudence to support its conclusion, and thus merely makes a bare assertion. The ponencia fails to consider that under RA 9225, natural-born citizens who were deemed to have lost their Philippine citizenship because of their naturalization as citizens of a foreign country and who subsequently complied with the requirements of RA 9225, are deemed not to have lost their Philippine citizenship. RA 9225 cured and negated the presumption made under CA 63. Hence, as in Japzon, Arnado assumed “pure” Philippine citizenship again after taking the Oath of Allegiance and executing an Oath of Renunciation of his American citizenship under RA 9225. In this light, the proper framing of the main issue in this case should be whether Arnado’s use of his US passport affected his status as a “pure” Philippine citizen. In question form – did Arnado’s use of a US passport amount to a ground under the law for the loss of his Filipino citizenship under CA 63? Or alternatively, the retention of his dual citizenship status? I loathe to rule that Arnado’s use of his US passport amounts to an express renunciation of his Filipino citizenship, when its use was an isolated act that he sufficiently explained and fully justified. I emphasize that the law requires express renunciation in order to lose Philippine citizenship. The term means a renunciation that is made distinctly and explicitly and is not left to inference or implication; elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/55820 43/49