Reacquiring Philippine Citizenship Thru Repatriation

Photo is for illustration purposes only, not connected to the digested case. Courtesy of

257 SCRA 727
FACTS : Frivaldo obtained the highest number of votes in 3 successive elections but was twice declared by the Supreme Court to be disqualified to hold office due to his alien citizenship. He now claims to have re-assumed his lost Philippine citizenship thru repatriation. It was established that he took his oath of allegiance under the provisions of PD 725 on June 30, 1995, much later than the time he filed his Certificate of Candidacy.

ISSUE : Whether or not Frivaldo reacquired his Phil citizenship thru repatriation.

HELD : Yes. Under Phil. law citizenship may be reacquired by direct act of Congress, by naturalization or repatriation. The law does not specify any particular date or time when the candidate must possess citizenship, unlike that for residence and age. The Supreme Court holds that the repatriation of Frivaldo retroacted to the date of the filing of his application on August 17, 1994. Being a former Filipino, he deserves a liberal interpretation of Philippine Laws and whatever defects there were in his nationality should be deemed mooted by his repatriation.

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