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 for and was elected as the Representative of the Second District of Pangasinan in the 1998 elections, defeating petitioner Antonio Bengson III.
Petitioner filed a Quo Warranto Ad Cautelam with the House of Representatives Electoral Tribunal (HRET), contending that Cruz was not a natural-born citizen and thus disqualified under Article VI, Section 6 of the Constitution . The HRET dismissed the petition, declaring Cruz the duly elected Representative. Bengson filed the present petition for certiorari, arguing the HRET committed grave abuse of discretion in ruling that Cruz reacquired his natural-born status through repatriation.

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 citizenship 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 distinction between natural-born citizens and naturalized citizens. Natural-born citizens are those who are citizens from birth without performing any act to acquire or perfect citizenship. Naturalized citizens acquire citizenship through a legal process.
Repatriation under R.A. No. 2630 simply restores a person’s original citizenship. It is a minimal, non-discretionary administrative process for returning Filipinos who lost citizenship. It is not naturalization, which is a substantive proceeding conferring citizenship for the first time. Since Cruz was originally a natural-born citizen, his repatriation merely reinstated his prior status; it did not constitute an initial acquisition of citizenship. Therefore, he reverted to being a natural-born Filipino. The constitutional requirement for membership in the House of Representatives is thus satisfied. The HRET did not commit grave abuse of discretion, as its ruling correctly interpreted the legal effect of repatriation on one’s original citizenship classification.