Bengson v. Cruz
CLARIFICATIONFacts
1. The Antecedents: Respondent Teodoro C. Cruz, born a natural-born Filipino citizen to Filipino parents, later enlisted in the United States Marine Corps and took an oath of allegiance to the United States. Subsequently, he became a naturalized U.S. citizen. Commonwealth Act No. 63, Section 1(4) provides that a Filipino citizen may lose citizenship by rendering service to or accepting a commission in the armed forces of a foreign country. Cruz reacquired his Filipino citizenship through repatriation under Republic Act No. 2630. 2. Procedural History: After reacquiring his Filipino citizenship, Cruz ran for and was elected as the Representative of the Second District of Pangasinan. Petitioner Antonio Bengson III filed a quo warranto petition with the House of Representatives Electoral Tribunal (HRET), arguing Cruz was not qualified as he is not a natural-born citizen. The HRET dismissed the petition, upholding Cruz's qualification. The HRET subsequently denied Bengson's motion for reconsideration. 3. The Petition: Petitioner Bengson filed the present petition for certiorari with the Supreme Court, assailing the HRET's decision. He argues that the HRET committed grave abuse of discretion by ruling that Cruz is a natural-born citizen, despite his loss and subsequent reacquisition of citizenship. Bengson contends that the reacquisition through repatriation could not restore his natural-born status, as the Constitution requires citizenship from birth without performing any act to acquire or perfect it. The core issue is whether repatriation restores one's original status as a natural-born citizen.
Issue(s)
Whether or not respondent Cruz, a former natural-born Filipino who lost his citizenship by serving in the U.S. Armed Forces and becoming a U.S. citizen, and who later reacquired it through repatriation, is considered a natural-born citizen qualified to be a Member of the House of Representatives.
Ruling
WHEREFORE, the petition is hereby DISMISSED.
Ratio Decidendi
On the issue of respondent Cruz's citizenship status: Yes, respondent Cruz is considered a natural-born citizen of the Philippines. The Supreme Court held that repatriation results in the recovery of the original nationality. This means that if a person was originally a natural-born citizen before losing their citizenship, they are restored to their former status as a natural-born Filipino upon repatriation. The Court distinguished repatriation from naturalization. Naturalization is a mode of acquiring a new citizenship, while repatriation is a mode of recovering a former one. The constitutional definition of a natural-born citizen as one who is a citizen 'from birth without having to perform any act to acquire or perfect his Philippine citizenship' does not preclude a repatriated individual from being considered natural-born. The 'act' referred to in the Constitution is the process of naturalization or the election of citizenship, not the simplified act of taking an oath for repatriation. The Court further reasoned that the Constitution enumerates only two classes of citizens: natural-born and naturalized. Since respondent Cruz did not undergo the process of naturalization to reacquire his citizenship, he is not a naturalized citizen. Therefore, he is necessarily a natural-born Filipino, restored to the status he held at birth. Finally, the Court affirmed that the HRET is the 'sole judge' of its members' qualifications, and its decision can only be overturned upon a clear showing of grave abuse of discretion, which was absent in this case.
Main Doctrine
Repatriation is a mode of reacquiring citizenship that results in the recovery of the person's original nationality. A natural-born Filipino citizen who loses their citizenship and subsequently reacquires it through repatriation is restored to their former status as a natural-born Filipino. The act of taking an oath of allegiance to reacquire citizenship does not fall under the constitutional prohibition of 'having to perform any act to acquire or perfect' citizenship, as this phrase pertains to the process of naturalization or the election of citizenship. The Constitution only recognizes two classes of citizens: natural-born and naturalized; a repatriate who was not naturalized is necessarily restored to their original natural-born status.