Mercado vs Manzano

G.R. No. 135083, 26 May 1999 [Dual Citizenship; Dual Allegiance]

FACTS:
Petition for disqualification was filed against Edu Manzano to hold elective office on the ground that he is both an American citizen and a Filipino citizen, having been born in the United States of Filipino parents. COMELEC granted the petition and disqualified Manzano for being a dual citizen pursuant to the Local Government Code RA 7160, that those with dual citizenship are disqualified from running any public position.

ISSUE:
Whether or not dual citizenship is a ground for disqualification to hold or run office in the local position.

RULING:
No. Dual citizenship is different from dual allegiance. What is inimical is not dual citizenship per se, but with naturalized citizens who maintain their allegiance to their countries of origin even after their naturalization. Hence, the phrase “dual citizenship” in RA 7160 must be understood as referring to “dual allegiance”. Consequently, persons with mere dual citizenship do not fall under this disqualification.