Mercado vs. Manzano, G.R. No.

135083, May 26, 1999

FACTS: Mercado and Manzano are both running for vice-mayor of Makati City.
Manzano got the highest number of votes but his proclamation was suspended in
view of a pending petition for his disqualification on the ground that he is an
American citizen. Manzano is born in 1955 of Filipino father and mother. However,
since he is born in the US, he is considered as an American under the jus soli
doctrine. Upon his return to the Philippines, he is registered as a foreigner with the
Bureau of Immigration.
ISSUE: Whether or not Manzano is disqualified on ground that he is an alien
HELD: Manzano is a dual citizen, but his being such does not disqualify him from
running for public office. Under the LGC, what is prohibited is dual allegiance and
not dual citizenship. The two terms are different.
Dual allegiance refers to a situation in which a person simultaneously owes, by
some positive act, loyalty to two or more states. Dual citizenship arises when, as a
result of the concurrent application of the different laws of two or more states, a
person is simultaneously considered a national by the said states.
Moreover, Manzano is considered to have renounced his American citizenship by
filing his certificate of candidacy.