CASE 7: Calilung v. Secretary of Justice (G.R. No. 160869, May 11, 2007)

Republic Act No. 9225 (Citizenship Retention and Reacquisition Act of 2003)

A law allowing natural-born Filipinos who became foreign citizens to retain or reacquire their Philippine citizenship upon taking an oath of allegiance to the Republic.

Natural-Born Citizen (Article IV, Section 2, 1987 Constitution)

A person who is a citizen of the Philippines from birth without having to perform any act to acquire or perfect their citizenship. The Court ruled that reacquisition under R.A. No. 9225 does not automatically restore natural-born status.

Dual Citizenship vs. Dual Allegiance (Article IV, Section 5, 1987 Constitution)

Dual citizenship arises due to conflicting nationality laws, while dual allegiance refers to a person's conscious commitment to two states, which is deemed inimical to national interest. The Court ruled that R.A. No. 9225 does not promote dual allegiance.

Oath of Allegiance Requirement (Section 3, R.A. No. 9225)

Natural-born Filipinos who acquire foreign citizenship may reacquire Philippine citizenship by taking an oath of allegiance to the Philippines. This does not automatically require renunciation of foreign citizenship unless running for public office.

Derivative Citizenship (Section 4, R.A. No. 9225)

Unmarried children below 18 of those who reacquire Philippine citizenship also become Filipino citizens, ensuring family unity.

Qualifications for Elective Office (Section 5(2), R.A. No. 9225)

Filipinos who reacquire citizenship and seek elective office must renounce their foreign citizenship upon filing their Certificate of Candidacy (COC).

Prohibition Against Public Office for Foreign Citizens (Section 5(3), R.A. No. 9225)

Reacquired citizens appointed to public office must take an oath of allegiance to the Philippines and renounce their foreign citizenship before assuming office.

Distinction Between Mercado v. Manzano and Calilung v. Secretary of Justice

In Mercado, the Court distinguished dual citizenship from dual allegiance but did not define acts constituting dual allegiance, which remains a legislative matter.