CASE 9: Bengson III v. HRET & Cruz (G.R. No. 142840, May 7, 2001)

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 repatriation restores one’s original natural-born status.

Loss of Philippine Citizenship (Commonwealth Act No. 63, Section 1(4))

A Filipino citizen loses their Philippine citizenship by rendering service to or accepting a commission in the armed forces of a foreign country, unless done with the Philippine government’s consent.

Effect of Naturalization in a Foreign Country

Cruz lost his natural-born Filipino status when he became a U.S. citizen while serving in the U.S. Marine Corps.

Repatriation (Republic Act No. 2630)

A law that allows former Filipinos who lost citizenship due to service in the U.S. Armed Forces to reacquire Philippine citizenship by taking an oath of allegiance and registering it with the civil registry.

Repatriation Restores Original Citizenship Status

The Court ruled that repatriation restores a person’s former status. Since Cruz was originally a natural-born citizen, his repatriation restored his natural-born status.

Qualifications for Elective Office (Article VI, Section 6, 1987 Constitution)

Members of the House of Representatives must be natural-born Filipino citizens. The Court ruled that Cruz met this requirement after his repatriation.

HRET as Sole Judge of Electoral Contests (Article VI, Section 17, 1987 Constitution)

The House of Representatives Electoral Tribunal (HRET) has exclusive jurisdiction over election contests involving House members, and the Supreme Court can only review its decisions for grave abuse of discretion.

Distinction Between Naturalization and Repatriation

Naturalization is a process granting citizenship to an alien, while repatriation restores the original citizenship of a former Filipino. The latter does not require a naturalization process.

Affirmation of Popular Sovereignty

The Court emphasized that in cases of doubt, the decision should favor the electorate’s will. Since Cruz was overwhelmingly elected, any ambiguities in citizenship law should be resolved in favor of his eligibility.