Citizenship of Foreign
Citizenship of Foreign
Citizenship of Foreign
Petitioner Sobejano-Condon was a natural-born Filipino citizen on August 8, 1944 but became a naturalized Australian citizen due to her
marriage to one Kevin Thomas Condon on December 13, 1984. On December 2, 2005, she filed an application to re-acquire Philippine
citizenship before the Philippine Embassy in Canberra, Australia pursuant to Sec. 3 of RA 9225, which was approved and she took her
oath of allegiance to the Republic on December 5, 2005.
On September 18, 2006, petitioner filed an unsworn Declaration of Renunciation of Australian Citizenship before the Department of
Immigration and Indigenous Affairs, Canberra, Australia, which in turn issued the order dated September 27, 2006 certifying that she
has ceased to be an Australian citizen.
She ran for Mayor in her hometown of Caba, La Union in 2007 elections but lost her bid. She ran again and won in the May 2010 elections,
this time for position of Vice-Mayor, and took her oath on May 13, 2010. However, private respondents Luis M. Bautista, et al., all
registered voters of Caba, La Union, filed separate petitions for quo warranto questioning her eligibility before the RTC on the issue of
her dual citizenship and that she failed to execute “a personal and sworn renunciation of any and all foreign citizenship before any public
officer authorized to administer an oath.”
RA 9225 provides that a Filipino American or any dual citizen cannot run for any elective public position in the
Philippines unless he or she personally swears to a renunciation of all foreign citizenship at the time of filing the
certificate of candidacy. We also expounded on the form of the renunciation and held that to be valid, the
renunciation must be contained in an affidavit duly executed before an officer of the law who is authorized to
administer an oath stating in clear and unequivocal terms that affiant is renouncing all foreign citizenship.
The petitioner's failure to comply therewith in accordance with the exact tenor of the law, rendered ineffectual the
Declaration of Renunciation of Australian Citizenship she executed on September 18, 2006. Such renunciation
made by her in Australia was not under oath contrary to the exact mandate of Section 5(2) that the renunciation of
foreign citizenship must be sworn before an officer authorized to administer oath.