Case Digest (G.R. No. 221697) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Rizalito Y. David challenged the senatorial qualifications of private respondent Mary Grace Poe-Llamanzares, a foundling whose biological parents remain unknown. On September 3, 1968, she was discovered as an infant outside the Parish Church of Jaro, Iloilo, and subsequently registered as a foundling. In 1974, she was adopted by spouses Ronald Allan Poe (Fernando Poe Jr.) and Jesusa Sonora Poe (Susan Roces) through a final decision of the San Juan Municipal Court. She thereafter used her foundling certificate and amended birth record to register as a voter (1986), secure a Philippine passport (1988 and renewals), and pursue her education abroad. In 1991 she became a naturalized American citizen, held a U.S. passport, and gave birth to three children. On July 7, 2006, she took the Oath of Allegiance under Republic Act No. 9225, petitioned for re-acquisition of Philippine citizenship, and was deemed to have reacquired her natural-born status. She renounced U.S. citizens Case Digest (G.R. No. 221697) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Certification
- Mary Grace Poe-Llamanzares was abandoned as an infant on September 3, 1968 outside the Parish Church of Jaro, Iloilo, and issued a Foundling Certificate by the Local Civil Registrar.
- In 1974, the Municipal Court of San Juan, Rizal, granted her adoption by Fernando Poe Jr. and Susan Roces, changing her surname to Poe.
- Education, Personal Life, and U.S. Naturalization
- She studied at UP Manila and earned a Political Science degree from Boston College in 1991.
- Married an American-Filipino in 1991, lived in the U.S., and was naturalized as a U.S. citizen on October 18, 2001.
- Reacquisition of Philippine Citizenship
- On July 7, 2006, she took the Oath of Allegiance under RA 9225, and on July 18, 2006, the Bureau of Immigration granted her petition to reacquire Philippine citizenship.
- She registered to vote in San Juan, Metro Manila, on August 31, 2006.
- Senate Candidacy and SET Proceedings
- Filed COC for Senator in October 2012, elected in May 2013.
- Petitioner Rizalito Y. David filed a quo warranto before the Senate Electoral Tribunal (SET) in August 2015, alleging she was not a natural-born citizen.
- On November 17, 2015, the SET dismissed the petition, finding her a natural-born citizen; on December 3, 2015, it denied reconsideration.
- Supreme Court Certiorari
- David filed a Rule 65 petition for certiorari before the Supreme Court on December 9, 2015, seeking annulment of the SET’s resolutions.
- The case was argued on January 19, 2016, focusing on whether the SET gravely abused its discretion in upholding her natural-born status.
Issues:
- Jurisdictional Review
- Whether the SET acted without or in excess of its jurisdiction or with grave abuse of discretion in dismissing the quo warranto petition.
- Natural-Born Citizenship
- Whether a foundling with unknown parents can be a “natural-born citizen” under Article IV, Sections 1 and 2 of the 1987 Constitution.
- Effect of RA 9225
- Whether respondent’s compliance with RA 9225 affects her natural-born status and qualification for the Senate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)