Aznar vs COMELEC GR # 83820, May 25, 1990 (Constitutional Law Alien, Loss of Citizenship) FACTS: In the case at bar,

, petitioner challenged respondents right to hold public office on the ground that the latter was an alien. Respondent maintains that he is a son of a Filipino, was a holder of a valid subsisting passport, a continuous resident of the Philippines and a registered voter since 1965. He was, however, also a holder of an alien registration certificate. ISSUE: Whether or not respondent is an alien. HELD: No, because by virtue of his being a son of a Filipino, it is presumed that he was a Filipino and remained Filipino until proof could be shown that he had renounced or lost his Philippine citizenship. In addition, possession of an alien registration certificate unaccompanied by proof of performance of acts whereby Philippine citizenship had been lost is not adequate proof of loss of citizenship.

Yu vs Defensor-Santiago Doctrine: Reacquisition of citizenship FACTS: Petitioner Yu, originally a Portuguese national, was naturalized as a Philippine citizen on 10February 1978. However, on 21 July 1981, petitioner applied for and was issued a renewed PortuguesePassport No. 35/81 serial N. 1517410 by the Consular Section of the Portuguese Embassy in Tokyo. SaidConsular Office certifies that his Portuguese passport expired on 20 July 1986.The CID detained the petitioner pending his deportation case. The petitioner, in turn, filed a petition forhabeas corpus. An internal resolution of 7 November 1988 referred the case to the Court en banc. ISSUE: Whether or not petitioners acts constitute renunciation of his Philippine citizenship HELD: Yes. Philippine citizenship, it must be stressed, is not a commodity or were to be displayed whenrequired and suppressed when convenient. Petitioner, while still a citizen of the Philippines who hadrenounced, upon his naturalization, "absolutely and forever all allegiance and fidelity to any foreignprince, potentate, state or sovereignty" and pledged to "maintain true faith and allegiance to theRepublic of the Philippines," he declared his nationality as Portuguese in commercial documents

hesigned, specifically, the Companies registry of Tai Shun Estate Ltd. 20 filed in Hongkong sometime inApril 1980. Express renunciation was held to mean a renunciation that is made known distinctly andexplicitly and not left to inference or implication. Petitioner, with full knowledge, and legal capacity,after having renounced Portuguese citizenship upon naturalization as a Philippine citizen resumed orreacquired his prior status as a Portuguese citizen, applied for a renewal of his Portuguese passport andrepresented himself as such in official documents even after he had become a naturalized Philippinecitizen. Such resumption or reacquisition of Portuguese citizenship is grossly inconsistent with hismaintenance of Philippine citizenship.WHEREFORE, premises considered, petitioner's motion for release from detention is DENIED.Respondent's motion to lift the temporary restraining order is GRANTED. This Decision is immediatelyexecutory.While still a citizen of the Philippines who had renounced, upon his naturalization, "absolutely andforever all allegiance and fidelity to any foreign prince, potentate, state or sovereignty" and pledged to"maintain true faith and allegiance to the Republic of the Philippines," he declared his nationality asPortuguese in commercial documents he signed, specifically, the Companies registry of Tai Shun EstateLtd. filed in Hongkong sometime in April 1980.