Case Digest (G.R. No. 142840)
Facts:
In Antonio Bengson III vs. House of Representatives Electoral Tribunal and Teodoro C. Cruz (G.R. No. 142840, May 7, 2001), petitioner Antonio Bengson III challenged the qualification of Teodoro C. Cruz, elected Representative of Pangasinan’s 2nd District in May 1998. Cruz, born April 27, 1960 in San Clemente, Tarlac to Filipino parents, enlisted in the U.S. Marine Corps on November 5, 1985, and swore allegiance to the United States, thereby losing Philippine citizenship under Commonwealth Act No. 63, § 1(4). He was naturalized as a U.S. citizen on June 5, 1990. After his discharge in October 1993, Cruz took the Oath of Allegiance under Republic Act No. 2630 and registered it with the Magantarem, Pangasinan civil registry on March 17, 1994, reclaiming Philippine citizenship. Having served as Mangatarem mayor (1995–1998), he ran and won as congressman by a margin of 26,671 votes against Bengson. Bengson filed a quo warranto petition before the House Electoral Tribunal (HRET) allegCase Digest (G.R. No. 142840)
Facts:
- Early Citizenship and Military Service
- Teodoro C. Cruz born on April 27, 1960 in San Clemente, Tarlac, to Filipino parents, making him a natural-born citizen under the 1935 Constitution.
- On November 5, 1985, Cruz enlisted in the U.S. Marine Corps, took an oath of allegiance to the United States without Philippine consent, thereby losing Philippine citizenship under Commonwealth Act No. 63, § 1(4).
- Naturalized as a U.S. citizen on June 5, 1990, in connection with his U.S. military service; honorably discharged October 27, 1993.
- Reacquisition of Philippine Citizenship and Election
- On March 17, 1994, Cruz took the oath of allegiance under Republic Act No. 2630 (repatriation) and registered it in the Local Civil Registry of Mangatarem, Pangasinan, thereby reacquiring Filipino citizenship.
- Ran for and won as Representative of Pangasinan’s 2nd District in the May 11, 1998 elections by a margin of 26,671 votes over incumbent Antonio Bengson III.
- Bengson filed a Quo Warranto Ad Cautelam with the House of Representatives Electoral Tribunal (HRET), alleging Cruz was not a natural-born Filipino and thus disqualified.
- HRET Proceedings and Supreme Court Petition
- On March 2, 2000, HRET dismissed Bengson’s petition and declared Cruz duly elected; denied reconsideration April 27, 2000.
- Bengson filed a certiorari petition with the Supreme Court, alleging HRET committed grave abuse of discretion in:
- Declaring Cruz a natural-born citizen despite his loss and renunciation of citizenship;
- Finding Cruz validly reacquired Philippine citizenship;
- Holding that reacquisition restored his natural-born status.
Issues:
- Whether Teodoro C. Cruz remains a natural-born Filipino citizen after losing citizenship through U.S. military service and subsequently reacquiring it under RA 2630.
- Whether loss and repatriation preclude natural-born status under Article IV, § 2 of the 1987 Constitution.
- Whether HRET committed grave abuse of discretion amounting to lack or excess of jurisdiction in upholding Cruz’s natural-born status and election.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)