FRIVALDO VS. COMELEC, digested

GR # 87193, June 23, 1989 (Constitutional Law – Recovery of Citizenship)

FACTS: Private respondent questioned petitioner governor’s candidacy and election for being null and void ab initio due to his alienage. Petitioner governor contends that his active participation in the elections had divested him of American citizenship under the laws of the US, and restored him of his Philippine citizenship.

ISSUE: Whether or not the filing of a certificate of candidacy by a naturalized American effectively recovers his Philippine citizenship.

HELD: No, Philippine citizenship previously disowned is not that cheaply recovered. Citizenship once lost may be reacquired either by naturalization or repatriation or by direct grant by law (CA 63) which was not invoked by the petitioner.

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