4/20/2021 E-Library - Information At Your Fingertips: Printer Friendly treatise, Private International Law.[5] He defines repatriation as "the recovery of the original nationality upon fulfillment of certain conditions."[6] Webster buttresses this definition by describing the ordinary or common usage of repatriate, as "to restore or return to one's country of origin, allegiance, or citizenship; x x x."[7] In relation to our subject matter, repatriation, then, means restoration of citizenship. It is not a grant of a new citizenship, but a recovery of one's former or original citizenship. To "reacquire" simply means "to get back as one's own again."[8] Ergo, since Cruz, prior to his becoming a US citizen, was a natural-born Filipino citizen, he "reacquired" the same status upon repatriation. To rule otherwise – that Cruz became a non-naturalborn citizen – would not be consistent with the legal and ordinary meaning of repatriation. It would be akin to naturalization, which is the acquisition of a new citizenship. "New," because it is not the same as that with which he has previously been endowed. In any case, "the leaning, in questions of citizenship, should always be in favor of [its] claimant x x x."[9] Accordingly, the same should be construed in favor of private respondent, who claims to be a natural-born citizen. 1. Not Being Naturalized, Respondent Is Natural Born Second, under the present Constitution, private respondent should be deemed naturalborn, because was not naturalized. Let me explain. There are generally two classes of citizens: (1) natural-born citizens and (2) naturalized citizens.[10] While CA 63 provides that citizenship may also be acquired by direct act of the Legislature, I believe that those who do become citizens through such procedure would properly fall under the second category (naturalized).[11] Naturalized citizens are former aliens or foreigners who had to undergo a rigid procedure, in which they had to adduce sufficient evidence to prove that they possessed all the qualifications and none of the disqualifications provided by law in order to become Filipino citizens. In contrast, as stated in the early case Roa v. Collector of Customs,[12] a natural-born citizen is a citizen "who has become such at the moment of his birth." The assailed HRET Decision, penned by Mr. Justice Vicente V. Mendoza, explains clearly who are considered natural-born Filipino citizens. He traces the concept as first defined in Article III of the 1973 Constitution, which simply provided as follows: "Sec. 4. A natural-born citizen is one who is a citizen of the Philippines from birth without having to perform any act to acquire or perfect his Philippine citizenship." Under the above definition, there are two requisites in order that a Filipino citizen may be considered "natural-born": (1) one must be a citizen of the Philippines from birth, and (2) one does not have to do anything to acquire or perfect one's Philippine citizenship.[13] Thus, under the 1973 Constitution, excluded from the class of "naturalborn citizens" were (1) those who were naturalized and (2) those born before January https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/58613 11/25

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