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    Teodora Sobejana-Condon v. COMELEC (RPE)

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    Cindee Santiago
    Teodora Sobejana-Condon v. COMELEC (RPE) G.R. No. 198742. Aug. 10, 2012 Teodora was a natural born Filipino citizen who became an Australian citizen when she married. She reacquired her Philippine citizenship in 2005 but only filed an unsworn declaration renouncing her Australian citizenship. She ran for local office in 2007 and 2010. The court ruled she was ineligible because the Philippine Oath of Allegiance alone did not satisfy the requirement under RA 9225 to file a personal and sworn renunciation of foreign citizenship when running for elected office. A dual citizen must formally reject foreign citizenship through an affidavit sworn before an authorized

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    Teodora Sobejana-Condon v. COMELEC (RPE)

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    Cindee Santiago
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    Teodora Sobejana-Condon v. COMELEC (RPE) G.R. No. 198742. Aug. 10, 2012 Teodora was a natural born Filipino citizen who became an Australian citizen when she married. She reacquired her Philippine citizenship in 2005 but only filed an unsworn declaration renouncing her Australian citizenship. She ran for local office in 2007 and 2010. The court ruled she was ineligible because the Philippine Oath of Allegiance alone did not satisfy the requirement under RA 9225 to file a personal and sworn renunciation of foreign citizenship when running for elected office. A dual citizen must formally reject foreign citizenship through an affidavit sworn before an authorized

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    24. Teodora Sobejana-Condon v. COMELEC (RPE)

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    Teodora Sobejana-Condon v. COMELEC (RPE) G.R. No. 198742. Aug. 10, 2012 Teodora was a natural born Filipino citizen who became an Australian citizen when she married. She reacquired her Philippine citizenship in 2005 but only filed an unsworn declaration renouncing her Australian citizenship. She ran for local office in 2007 and 2010. The court ruled she was ineligible because the Philippine Oath of Allegiance alone did not satisfy the requirement under RA 9225 to file a personal and sworn renunciation of foreign citizenship when running for elected office. A dual citizen must formally reject foreign citizenship through an affidavit sworn before an authorized

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    50 views1 page

    Teodora Sobejana-Condon v. COMELEC (RPE)

    Uploaded by

    Cindee Santiago
    Teodora Sobejana-Condon v. COMELEC (RPE) G.R. No. 198742. Aug. 10, 2012 Teodora was a natural born Filipino citizen who became an Australian citizen when she married. She reacquired her Philippine citizenship in 2005 but only filed an unsworn declaration renouncing her Australian citizenship. She ran for local office in 2007 and 2010. The court ruled she was ineligible because the Philippine Oath of Allegiance alone did not satisfy the requirement under RA 9225 to file a personal and sworn renunciation of foreign citizenship when running for elected office. A dual citizen must formally reject foreign citizenship through an affidavit sworn before an authorized

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    Constitutional Law Review (Sunga)

    24. Teodora Sobejana-Condon v. The foreign citizenship must be formally rejected


    through an affidavit duly sworn before an officer
    COMELEC (RPE) authorized to administer oath.
    G.R. No. 198742. Aug. 10, 2012
    TOPIC: Citizenship In fine, R.A. No. 9225 categorically demands
    natural-born Filipinos who re-acquire their
    FACTS: citizenship and seek elective office, to execute a
    1. Teodora is a natural- born Filipino Citizen personal and sworn renunciation of any and all
    but she became a naturalized Australian foreign citizenships before an authorized public
    Citizen when she married Condon. officer prior to or simultaneous to the filing of
    2. On Dec. 2005, she filed an application to their certificates of candidacy, to qualify as
    re-acquire her Ph Citzenship in Philippine candidates in Philippine elections. The rule
    Embassy in Canberra, Australia and and applies to all those who have re-acquired their
    took her oath of allegiance in the Filipino citizenship, like petitioner, without
    Philippines. regard as to whether they are still dual citizens
    3. On Sept 2006, Teodora filed an or not. It is a pre-requisite imposed for the
    UNSWORN Declaration of Renunciation of exercise of the right to run for public office.
    Australian Citizenship.
    4. Teodora run for Mayor in Caba, La Union
    in the 2007 elections, but she lost her bid.
    During the 2010 elections, she run for
    Vice-Mayor and was proclaimed as the
    winning candidate.
    5. A quo warranto was filed against her:
    dual citizen and failed to execute a
    “personal and sworn renunciation of any
    and all foreign citizenship before any
    public officer authorized to administer an
    oath” as required by Sec (5)2 of RA 9225.
    6. RTC: rendered Teodora ineligible, the
    personal renunciation she filed in
    Australia was not under oath. COMELEC:
    Affirmed the RTC

    ISSUE: Whether the “the sworn renunciation of


    foreign citizenship” in Sec 5(2) of RA 9225 is a
    mere pro-forma requirement. – NO

    HELD:
    Teodora had validly re-acquired her Filipino
    Citizenship when she took an Oath of Allegiance
    to the Philippines. At that point, she became a
    dual citizen (Aussie & Filipino).

    However, a dual citizen cannot run for any


    elective public position unless he/she personally
    and explicitly renounce their foreign citizenship
    at the time of filing the certificate of candidacy.

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