G.R. No. 221697 & 221698-700, March 8, 2016
Mary Grace Natividad S. Poe-Llamanzares, Petitioner, vs. Commission on Elections (COMELEC) and Estrella C. Elamparo ( G.R. No. 221697 ); and COMELEC, Francisco S. Tatad, Antonio P. Contreras, and Amado D. Valdez (G.R. No. 221698-700), Respondents.

FACTS

Mary Grace Natividad S. Poe-Llamanzares (petitioner) was found as a newborn infant in Jaro, Iloilo, on September 3, 1968, and registered as a foundling. She was adopted by spouses Fernando Poe, Jr. and Susan Roces in 1974. She registered as a voter in the Philippines in 1986 and was issued Philippine passports in 1988, 1993, and 1998. She moved to the United States in 1988, married a Filipino-American citizen in 1991, and became a naturalized American citizen on October 18, 2001. Following her father’s death in late 2004, she and her family decided to resettle permanently in the Philippines. She returned to the Philippines on May 24, 2005, and undertook steps to establish permanent residence, including purchasing property, enrolling her children in school, and disposing of assets in the U.S. On July 7, 2006, she took an Oath of Allegiance to reacquire Philippine citizenship under Republic Act No. 9225 . She re-registered as a voter on August 31, 2006, and was issued a new Philippine passport. On October 20, 2010, she executed an Affidavit of Renunciation of her U.S. citizenship before assuming her appointment as Chairperson of the Movie and Television Review and Classification Board (MTRCB). She later filed her Certificate of Candidacy for President for the 2016 elections. The COMELEC, acting on various petitions, issued Resolutions cancelling her Certificate of Candidacy and denying her motion for reconsideration, primarily on the grounds that she failed to meet the constitutional requirements of natural-born citizenship and the ten-year residency for presidential candidates. The petitioner assailed these COMELEC Resolutions before the Supreme Court.

ISSUE

Whether the COMELEC committed grave abuse of discretion in cancelling petitioner’s Certificate of Candidacy on the grounds that she is not a natural-born Filipino citizen and failed to meet the ten-year residency requirement for President.

RULING

The Supreme Court GRANTED the petitions, reversed the assailed COMELEC Resolutions, and reinstated petitioner’s Certificate of Candidacy for President.
1. On Citizenship: The Court ruled that the petitioner is a natural-born Filipino citizen. As a foundling, she is presumed, under international law and domestic statutes, to be a natural-born citizen of the Philippines. This presumption, rooted in the principles of avoidance of statelessness and the best interests of the child, was not sufficiently rebutted by the respondents. Furthermore, her repatriation under R.A. No. 9225 and her subsequent renunciation of U.S. citizenship effectively restored her status as a natural-born Filipino citizen.
2. On Residency: The Court held that the petitioner satisfied the ten-year residency requirement. Her deliberate and concrete actions beginning in the first quarter of 2005—including her physical return on May 24, 2005, the sale of her U.S. home, the purchase of real property in the Philippines, the transfer of her family’s belongings, and the enrollment of her children in Philippine schools—demonstrated a clear intention to abandon her U.S. domicile and re-establish domicile in the Philippines. The period from May 24, 2005, to the day of the election on May 9, 2016, constitutes more than ten years and eleven months of residency.
The COMELEC committed grave abuse of discretion in disregarding this factual evidence and in ruling on the petitioner’s qualifications in a manner contrary to established jurisprudence and the intent of the constitutional provisions.