Title
Poe-Llamanzares vs. Commission on Elections
Case
G.R. No. 221697
Decision Date
Mar 8, 2016
Petition to disqualify Senator Poe-Llamanzares over citizenship claims dismissed; SC upheld SET's ruling, affirming her natural-born status as a foundling.

Case Summary (G.R. No. 221697)

Petitioner

Rizalito Y. David, a losing candidate in the 2013 senatorial elections, alleged that Poe lacked natural-born citizenship, and therefore did not meet Article VI, Section 3’s requirement for Senators.

Respondents

  1. Senate Electoral Tribunal – the constitutional body vested with exclusive original jurisdiction over contests relating to Senate members’ qualifications.
  2. Mary Grace Poe-Llamanzares – a foundling abandoned as an infant, subsequently adopted, naturalized U.S. citizen in 2001, who filed a petition under Republic Act No. 9225 to reacquire Philippine citizenship in 2006.

Key Dates

– September 3, 1968: Poe found as an infant at Jaro Parish Church, Iloilo.
– May 13, 1974: Adoption by Ronald Allan Poe and Jesusa S. Poe.
– October 18, 2001: Naturalized U.S. citizen.
– July 7, 2006: Took Oath of Allegiance under RA 9225.
– May 16, 2013: Declared Senator-elect.
– November 17, 2015: SET Decision dismissing quo warranto.
– September 20, 2016: Supreme Court En Banc Decision.

Applicable Law

– 1987 Constitution, Article IV, Sections 1–2 (citizenship definitions) and Article VI, Section 3 (Senator qualifications).
– Republic Act No. 9225 (Citizenship Retention and Re-acquisition Act of 2003).
– Rules of Court, Rule 65 (certiorari) and Rule 133 (substantial evidence).

Factual Findings

Poe’s birth parents remain unknown. She holds a foundling certificate, was lawfully adopted, became a U.S. citizen in 2001, and reacquired Philippine citizenship in 2006 by taking the statutory Oath of Allegiance. She has since voted, held public office, and satisfied all formal prerequisites for elective candidacy.

Senate Electoral Tribunal Ruling

Exercising its exclusive prerogative, the SET concluded that—despite unknown parentage—a reasonable inference of Filipino parentage is permissible under the Constitution’s purposive reading. It found Poe a natural-born citizen “from birth without having to perform any act to acquire or perfect” her citizenship, and thus dismissed David’s quo warranto petition.

Supreme Court Majority Decision

The Court held that:

  1. SET judgments on Senate qualifications are final except for grave abuse of discretion (Rule 65 certiorari).
  2. Article IV, Section 2 defines natural-born citizens; Section 1(2) merely enumerates who are citizens. The definition, not the enumeration, controls.
  3. Citizenship by jus sanguinis need not demand proof of full “blood line.” When a foundling’s parentage is unknown, the Constitution allows reasonable circumstantial inferences—e.g., abandonment as a newborn in 1968 Iloilo, prevailing Filipino demography, lack of international airport, physical features, and statistical probability—to conclude at least one Filipino parent.
  4. A presumption that foundlings are natural-born unless both parents can be proved non-Filipino protects children’s rights, equal protection, and equal access to public service, consistent with Articles II, III, XIII, and international treaties ratified by the Philippines.
  5. Poe, once naturalized abroad, validly reacquired her natural-born status under RA 9225 upon taking the Oath of Allegiance and meeting its post-reacquisition requirements.
  6. No grave abuse of discretion by the SET occurred. SET acted within its sole jurisdiction and rendered a reasoned interpretation of ambiguous constitutional text.

Dissenting Opinion (Justice Perlas-Bernabe)

  1. The 1935 Constitution—governing citizenship at Poe’s birth—followed strict ju

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