In Re Petition for Habeas Corpus of Willie Yu vs Miriam Defensor-Santiago

GR # L-83882, January 24, 1989 [Naturalization; Express renunciation]

FACTS: Willie Yu, despite his naturalization as a Philippine citizen, applied and renewed his Portuguese passport. Moreover, while still a citizen of the Philippines, petitioner also declared his nationality as Portuguese in commercial documents he signed.

ISSUE: Whether or not the acts of applying for a foreign passport and declaration of foreign nationality in commercial documents, constitute an express renunciation of one’s Philippine citizenship acquired through naturalization.

HELD: Yes, the foregoing acts considered together constitute an express renunciation of petitioner’s Philippine citizenship acquired through naturalization. In a related jurisprudence, express renunciation was held to mean a renunciation that is made known distinctly and explicitly and not left to inference or implication.