4/20/2021
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Section 1. Any person who had lost his Philippine citizenship be rendering
service to, or accepting commission in the Armed Forces of the United
States, or after separation from the Armed Forces of the United States,
acquired United States citizenship, may reacquire Philippine citizenship by
taking an oath of allegiance to the Republic of the Philippines and registering
the same with the Local Civil Registry in the place where he resides or last
resided in the Philippines. The said oath of allegiance shall contain a
renunciation of any other citizenship."
respondent Cruz had to perform certain acts before he could again become a Filipino
citizen. He had to take an oath of allegiance to the Republic of the Philippines and
register his oath with the Local Civil Registry of Mangatarem, Pangasinan. He had to
renounce his American citizenship and had to execute an affidavit of reacquisition of
Philipine citizenship.
Clearly, he did not reacquire his natural-born citizenship. The cardinal rule in the
interpretation and construction of a constitution is to give effect to the intention of the
framers and of the people who adopted it. Words appearing in a Constitution are used
according to their plain, natural, and usual significance and import and must be
understood in the sense most obvious to the common understanding of the people at
the time of its adoption.
The provision on "natural-born citizens of the Philippines" is precise, clear and definite.
Indeed, neither HRET nor this Court can construe it other than what its plain meaning
conveys. It is not phrased in general language which may call for construction of what
the words imply.
In J. M. Tuason & Co., Inc. vs. Land Tenure Administration,[6] this Court held:
"Ascertainment of meaning of provisions of Constitution begins with the
language of the document itself. The words used in the Constitution are to
be given their ordinary meaning, except where technical terms are
employed, in which case the significance thus attached to them prevails. As
the Constitution is not primarily a lawyer's document, it being essential for
the rule of law to obtain that it should ever be present in the people's
consciousness, its language as much as possible, should be understood in
the sense they have in common use. What it says according to the text of
the provision to be construed compels acceptance and negates the power of
the courts to alter it, based on the postulate that the framers and the people
mean what they say."
The definition of a natural-born citizen in the Constitution must be applied to this
petition according to its natural sense.
Respondent HRET likewise ruled that the "reacquisition of Philippine citizenship through
any of these modes: (naturalization, repatriation and legislation under Section 3, C.A.
No. 63) results in the restoration of previous status, either as a natural-born or a
naturalized citizen" is a simplistic approach and tends to be misleading.
If citizenship is gained through naturalization, repatriation or legislation, the citizen
concerned can not be considered natural-born. Obviously, he has to perform certain
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