Bengson III vs. House of Representatives Electoral Tribunal

Facts:

Antonio Bengson III v. House of Representatives Electoral Tribunal and Teodoro C. Cruz, G.R. No. 142840, May 07, 2001, the Supreme Court En Banc, Kapunan, J., writing for the Court. Petitioner Antonio Bengson III challenged the qualification of respondent Teodoro C. Cruz before the House of Representatives Electoral Tribunal (HRET) and ultimately before the Supreme Court.

Teodoro C. Cruz was born in San Clemente, Tarlac on April 27, 1960 to Filipino parents and thus was originally a natural‑born Filipino under the then‑applicable 1935 Constitution. On November 5, 1985 Cruz enlisted in the United States Marine Corps and took an oath of allegiance to the United States; under Commonwealth Act No. 63, Sec. 1(4) a Filipino who renders service in a foreign armed force may lose Philippine citizenship. Cruz was naturalized as a U.S. citizen on June 5, 1990 while in U.S. service.

After his U.S. discharge Cruz returned to the Philippines and, on March 17, 1994, reacquired Philippine citizenship by repatriation under Republic Act No. 2630 (taking an oath of allegiance and registering it in the local civil registry). He subsequently ran for and was proclaimed winner as Representative of the Second District of Pangasinan in the May 11, 1998 elections, defeating petitioner by 26,671 votes.

Petitioner filed a petition for Quo Warranto Ad Cautelam with the HRET arguing Cruz was not a natural‑born citizen as required by Article VI, Sec. 6 of the 1987 Constitution. On March 2, 2000 the HRET dismissed the quo warranto petition and declared Cruz duly elected; a motion for reconsideration was denied on April 27, 2000. Bengson then filed the present petition for certiorari with this Court, contending (1) HRET gravely abused its discretion in finding Cruz a natural‑born citizen despite his loss and renunciation of citizenship; (2) Cruz did not va...(Pro-only)

Issues:

• Did the HRET commit grave abuse of discretion amounting to lack or excess of jurisdiction in declaring Teodoro C. Cruz duly elected?
• Can a person who was a natural‑born Filipino, lost Philippine citizenship by service and naturalization abroad, and later reacquired Philippine citizenship by repatriation under R.A. No. 2630, be regarded as a natural‑born citizen and thus qualified to be a memb...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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