G.R. No. 142840. May 7, 2001.
ANTONIO BENGSON III, petitioner, vs. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and TEODORO C. CRUZ, respondents.

FACTS

Respondent Teodoro C. Cruz was a natural-born Filipino citizen. In 1985, he enlisted in the United States Marine Corps and took an oath of allegiance to the United States, thereby losing his Philippine citizenship under Commonwealth Act No. 63. He was later naturalized as a U.S. citizen in 1990. In 1994, he reacquired Philippine citizenship through repatriation under Republic Act No. 2630. Cruz then ran and won as the Representative for the Second District of Pangasinan in the 1998 elections. Petitioner Antonio Bengson III, his opponent, filed a Quo Warranto petition with the House of Representatives Electoral Tribunal (HRET), contending Cruz was disqualified as he was not a natural-born citizen, a constitutional requirement for members of the House.
The HRET dismissed the petition, declaring Cruz the duly elected Representative. Bengson filed a petition for certiorari before the Supreme Court, arguing that the HRET committed grave abuse of discretion. He asserted that Cruz, having lost his natural-born status by voluntarily acquiring foreign citizenship, could not regain it through repatriation, as repatriation merely restores citizenship but not the natural-born classification.

ISSUE

Whether a natural-born Filipino citizen who lost his citizenship by serving in and swearing allegiance to a foreign military, and later reacquired Philippine citizenship through repatriation, is restored to his natural-born status.

RULING

The Supreme Court DENIED the petition and AFFIRMED the HRET decision. The Court held that respondent Cruz is a natural-born citizen. The legal logic is anchored on the definition and modes of acquiring citizenship. Citizenship is acquired either by birth or by naturalization. Natural-born citizens are those who are citizens from birth without performing any act to acquire or perfect their citizenship. Repatriation, as a mode of reacquiring Philippine citizenship, results in the recovery of the original citizenship. The Court distinguished repatriation from naturalization. Naturalization is a process for aliens to acquire citizenship, while repatriation involves the recovery of a lost citizenship by a former Filipino. Since Cruz was originally a natural-born citizen, his repatriation restored him to his prior status as a natural-born Filipino. The act of repatriation simply cured the defect of his lost citizenship; it did not convert him into a naturalized citizen. The law does not downgrade his original status upon reacquisition. Therefore, having reacquired his citizenship through repatriation, Cruz recovered his natural-born status and was qualified to hold the office of Representative. The HRET did not commit grave abuse of discretion in so ruling.