Whether or not a foundling can be considered a Filipino citizen is something only the Supreme Court can clarify. Both sides have merit, but since we have a liberal Supreme Court, let’s assume that it declares Grace Poe a natural-born Filipino citizen.
She still has another problem – the ten-year residence requirement of the 1987 Constitution. Section 2 of Article 7 of the Constitution prohibits a person from being elected as president or vice-president if that person has not been a resident of the Philippines for at least ten years before the election. This may surprise some people but the actual legal definition for the word “year” is 365 days. If the time period is less than 365 days, then it is not yet a year. No one, not even the Supreme Court, can stretch this requirement even with legal acrobatics.
This is a problem for Poe because it is not clear if she would have been a Philippine resident for ten years by the 2016 Presidential Elections. In her Certificate of Candidacy for senator, Grace Poe alleged that she would have had residence in the Philippines for 6 years and 6 months on May 13, 2013 (therefore, she was a resident since November 2006). If that were the case then, by the 2016 Presidential Elections, she would have been a Philippine resident only for around nine years and six months. That disqualifies her from running for president or vice-president.
When Grace Poe left the country to become a citizen of the United States, she renounced not just her Filipino citizenship, but also her residency in the Philippines (as explained by the Supreme Court in Japzon v. COMELEC ). In fact, she renounced her residency even before she became a citizen of the US, i.e., when she obtained a green card that would allow her permanent residence there. These are explicit acts which leave no room for doubt on what she was leaving behind. In 2005, when she entered the country, she used a US passport. There is no proof that she was a Filipino at this point.
To prove that she is Filipino, she has to show that she has an Identification Certificate (IC) issued by the Bureau of Immigration (BI) and, if applicable, the Certificate of Affirmation of Citizenship issued by the Department of Justice (if her IC was issued before the implementing rules of Republic Act No. 9225, “The Citizenship Retention and Re-acquisition Act of 2003”). This indicates the date she took her Oath of Allegiance (taking of the Oath is the act that confers citizenship).
Before she took her Oath, the State, by virtue of the Philippine Immigration Act, considered her an alien. Under Philippine law, aliens cannot be residents in the Philippines unless they are admitted as immigrants under Section 13 of the Philippine Immigration Act. And even if she were admitted into the country as a section 13 alien, her residency won’t count as residence for election purposes because she was not allowed to exercise political rights like the right to vote and the right to hold public office.
Residence in the context of political law is different from the usual definition of residence (which everyone knows as the place where one actually lives). Residence in political law is the place where one wishes to return to – the so-called animus revertendi. This means that a person can actually be living for several years in Manila or in Hawaii, but can still be considered to have residence (in the political sense) in Leyte because she has an animus to revert there. Weird as it may seem, that’s essentially what the Supreme Court ruled.
Some lawyers have said that if Grace Poe became a citizen only in November 2006, she should be considered to be a resident even before she regained her citizenship by virtue of the animus revertendi principle. Essentially, they say that she may have relinquished her Filipino citizenship, but that she never lost the desire to return to her country; hence, she never lost her residency. That position runs counter to a Supreme Court decision.
The residence of a person can only be counted from the time one enters the country to regain his residency (domicile) AND when one becomes a citizen (see Japzon v. COMELEC). That is the only time that one has all the rights granted by the constitution – all civil and political rights.
Secondly, since by legal principle, aliens cannot be residents of the Philippines (unless they are considered immigrants with section 13 visas), then no stretch of legal fiction would allow an alien to use the principle of animus revertendi to establish residence or domicile here. It is just legally impossible. The law cannot recognize a will to return to someplace that the alien has no right to be in.
When Poe came back, she used her US Passport, and it was stamped with a visa permitting her to stay here as a guest (either as a temporary visitor or a permanent one). There is no press release of any date when she took her Oath of Allegiance and regained her status as natural-born Filipino citizen.
To prove her residence, she just has to show when she took her Oath of Allegiance (the IC is best proof that, and if applicable, the DOJ Certificate of Affirmation) and when she started living in the Philippines. That’s it. One can count the years, months, and days from there. Of course, if she does not have an IC, then she has no right to even be Senator.
There is a report that Grace Poe used her US Passport in 2009 and even had it renewed in 2011. She also filed her renunciation of her US citizenship only in the second quarter of 2012.
The law on citizenship re-acquisition and retention does NOT require her to renounce her US citizenship to obtain all the rights accorded to a Filipino citizen. According to the law, conferment of citizenship is upon taking the Oath of Allegiance. Does it mean that she would have all the political rights of a citizen at that point when she took her Oath? Yes, it does.
Section 5(2) of Republic Act No. 9225 requires that, “Those seeking elective office in the Philippines shall meet the qualification for holding such public office as required by the Constitution and existing laws and at the time of filing of the certificate of candidacy, make a personal and sworn renunciation of any and all foreign citizenship before any public officer authorized to administer an oath.”
Grace Poe obviously made a sworn renunciation of foreign citizenship, based on the fact that there is on record an application for renunciation filed with the US government in the second quarter of 2012. If she could show that she filed for renunciation before she filed her certificate of candidacy, then there is no problem. Based on the facts, she can’t run for president or vice-president, but at least she can keep her Senate seat.
There really is just one hitch. The BI can still revoke her citizenship at this point because of something she did not do. And if her citizenship is revoked because of it, then she would have no right to serve in public office, whether as a Senator or in any other capacity.
Section 5(3) of Republic Act No. 9225 requires that, “Those appointed to any public office shall subscribe and swear to an oath of allegiance to the Republic of the Philippines and its duly constituted authorities prior to assumption of office. Provided, That they renounce their oath of allegiance to the country where they took that oath.”
Grace Poe was appointed to public office in 2010, but she did not renounce her allegiance to the US as she was required to by law. In fact, she used her US passport and even renewed it in 2011 AFTER her appointment to a public office. In a 2013 case, the Supreme Court declared that a public officer effectively recanted his oath of renunciation when he continued to use his US passport even after he has renounced his US citizenship. This meant that, at the time, the person had considered himself a citizen of the US.
If Grace Poe indeed made executed an Oath of Renunciation when she became a public official in 2010, she effectively recanted it when she used her US passport in 2011. After that, she only officially renounced her US citizenship in the second quarter of 2012. In fact, she only got a Philippine passport in 2014, a year after she became senator.
BI regulations allow revocation of citizenship upon a substantive finding of fraud, misrepresentation, or concealment on part of the applicant. Can there be such a finding in this case? That’s up to the BI now.
Laws and Men 
A very good explanation, easy to understand for a non legal person like me. Thanks Atty Dizon!
You’re welcome! Thanks for the feedback.
Reblogged this on Development templates for Guinarona.
Thanks for enlightening us re the issue, Atty, P.M. Dizon.
Salamat po.
That will be a good lesson to others if this case will be given a correct judgement! Thank you! I hope it will be good for the Philippines!
Very informative. Thank you!
What if she will apply for a dual citizenship?
As a senator, she is not allowed to become a dual citizen. She has to renounce her US citizenship. That is what she did.
My questions are
(1) When did she apply for dual citizenship?
(2) Does she have an IC to prove it?
(3) When did she file her renunciation of US citizenship
this is very helpful information, hope grace can read this too
With all due respect, former chief justice Artemio Panganiban has written extensively in his column in the Inquirer on Poe’s eligibility citizenship and residency issues and arrived at the conclusion that these should be legally resolved in her favor. Whether or not she availed of RA 9225 to reacquire Filipino citizenship or simply relied on the formal oath of renunciation before authorized Philippine goverment officials prior to her MTCRB appointment to reacquire natural born citizenship is a fact that has not been established. If she did not avail of RA 9225, she stll should have me or will meet he citizen requirements for her senate and prospective presidential candidacy. If you read Judge Panganiban’s opinion pieces, he reasons Poe should also pass residency requirements and he cites two Supreme Court cases in support of his conclusion, Japzon vs. COMELEC, which according to him affirms that domicile can be established by a former Filipino who by foreign naturalization loses his citizenship prior to availing of RA 9225. He also cites Cordora vs COMELEC which according to him is jurisprudence supporting how foreigners can establish domicile in the Philippines regardless of their citizenship.
In either case, it is clear that the residency requirements can be met by establishing domicile or intent thereof OR legal residency as may be defined by Philippine immigration law and which may or may not have been possible for Poe if she indeed was a US national and an alien prior to renouncing her US citizenship sometime before or during 2010, had she not become a dual citizen prior to that. She could also have been considered an alien resident with all the restrictions and privileges our imigration permits but the main point here is the concept of domicile under the Omnibus Election Code is what is sufficient for Poe to meet residency requirements.
Two other points are worth addressing with respect to her usage of a US passport that may invalidate her 2010 oath of renunciation and revoke her Philippine citizenship First of all, according to Bureau of Immigration records who presumably have copies of her US passport and entries thereon, the last use of it was in December 2009, prior to her oath of renunciation. Secondly, this passport which had a 2011 expiration could not have been possibly used or renewed after her visit to the US embassy sometime in 2010 to start the US process of giving up her citizenship. Under US department of state regulations, the first steps in in this process is handing in one’s US passport to consular officials.
I don’t get to read Justice Panganiban’s articles but I’m sure that his works are quite scholarly. I do not understand, though, how he can make those pronouncements without knowing important facts about the case. But thank you for writing. I would like to clarify some points for you to help you understand better the issue on Grace Poe’s residency.
1. Whether or not Poe used RA 9225 to re-acquire her citizenship is not known. She seems to want to keep this a big secret. This will determine IF she is actually a citizen of the Philippines AND the exact date she became a citizen. This is important in determining her residency.
2. My write-up was based on the Japzon vs COMELEC case. If you would read the case, you’ll see that it says exactly what I wrote – to establish residency, the person must first become a citizen and then return to the Philippines to establish his residence.
3. The Cordora vs COMELEC case is not applicable here. The Supreme Court itself declared that it was applicable only to dual citizens and is different from the Japzon case. The Supreme Court noted that the Japzon case was in reference to citizens who lost their citizenship and re-acquired it. In the Cordora case, the person establishing residence was not a foreigner – he was a dual citizen.
4. Therefore, it is clear that to qualify for residency under our election laws, she has to prove WHEN she re-acquired Filipino citizenshop AND when she went to the Philippines to establish her residency.
5. Regarding your point on Grace Poe’s U.S. passport… I never wrote that her passport expired on 2011. I said that there were reports that she had her U.S. passport renewed in 2011, specifically, that the Washington Passport Agency used her U.S. passport on December 2011. This was after she supposedly renounced her U.S. citizenship in 2010. If indeed that were the case, then that means that her renunciation would be considered void and of no effect.
6. Since she got issued a U.S. passport in December 2011, that means that she did not file for renunciation of citizenship with the U.S. government in 2010. That means… She has a problem. As you wrote, the first step in the process is handing over the passport to the US consular officials. That means that she started the process only after December 2011.
http://opinion.inquirer.net/byline/-artemio-v.-panganiban
Thank you for your response. With all due respect, I wanted to bring the opinions and conclusions of Chief Justice Panganiban to your attention because he is one of the leading judicial and legal authorities on constitutional law and his intent was to weigh in given his very considerable reputation on the issue of Poe’s eligibility for her current senate position or that of predident of this republic. I am furnishing a link to the four articles he published in the Inquirer for your convenience at the beginning of this response. The articles were were written from June 14 to July 5.If you read it carefully, you will observe his analysis goes counter to much of what you have stated in your piece and in your comments above. According to his analysis, including his citation of Japzon vs. Comelec and Cordero vs. Comelec and what these cases establish as relevant jurisprudence in so far as domicile is concerned, he is of the legal opinion that Poe should satisfy the presidential citizenship and residential candidacy requirements. As chief justice, his job day in and day out was to review established jurisprudence so it is no small matter that he should cite these two cases in support of his conclusions and analysis.
With respect to the individual points enumerated in your response, I respectfully submit the following comments:
I should mention that I am in general agreement with the facts he uses in analysis and I question sone of the facts you assume in yours as I might have mentioned in my first response to you. For instance, it is a verifiable fact that Poe initiated the process with the US embassy or consular office to renounce her US citizenship sometime in 2010 in which she gave up possession of her US passport. This is established by the fact that the IRS released an official list of persons who were officially stripped of their US citizenship snd Poe’s name was on that list. Secondly, Poe was never issued or could not have renewed her US passport in 2011 for reasons just cited. Earlier this year, a newspaper erred in reporting that Poe’s US passport was reissued in 2011 based on a faulty reading of a small photo of the data page of the passport she handed to US consular officials in 2010. That photo when magnified shoed the passport was actually issued in 2001 and expired in 2011, reflecting the standard 10 year life of a US passport. Moreover,when Poe performed her act of renunciation prior to her MTCRB job, as I mentioned in a my first response she submitted a copy of her US passport with all its entries and the last use was in December 2009 according to the BOI abd this is the data Justice Panganiban uses in his analysis.
1. Whether or not Poe used RA 9225 to reacquire her citizenship and become a dual citizen is irrelevant. If she did not, she reverted to a natural born citizen when she took an oath of renunciation prior to starting her job at the MTRCB. Many lawyers think the SC in the Maquiling case only ruled that the continued use of a passport negates the oath of renunciation taken by a Filipino to revert to a natural born citizen. In fact a careful reading of Maquiling that a proper oath of renunciation is all that is required to restore citizenship which is perhaps what lawyers told Poe to say in front of the press Knownfacts though is that the last use of Poe’s US passport occurred in 2009 before her renunciation. In any event, even if the impossible happened and by some miracle Poe inspite of her US citizenship being stripped got hold a passport and used it, according to Panganiban, all she has to do is to redo the oath of renouncement of her US citizenship and that remedies the situation.
I also disagree and so does Chief Justice Panganiban with your statement that the exact date of Poe’s citizenship is important in determining the duration of her residency. In fact I mentioned this in my first response above and tried to explain maybe unsuccessfully that the concept of domicile is quite different from the concept of legal residency whi h you have been tying to the need for Poe becoming a citizen fore the residency timer starts ticking. This is just not so and there is substantial jurisprudence establishing that one can establish domicile in countries where one is not a citizen of. In fact if you read the ponencia of Japzon vs. Comelec it clearly states that domicile OR legal residency can be used with respect to determining eligibility based on ldngth of residence. This probably explains why Chief Justice Panganiban cited Japzon in support of his analysis and conclusion whereas you maintai it supports your conclusion which is opposite of his.
2. See my last paragraph in 1 above re Japzon vs Comelec.
3. When Justice Panganiban wrote his essays, there was no speculation that Poe might not have used RA 9225 to become a dual citizen in 2004 when she came back to help with FPJ’s campaign where citizenship and her right to vote for her father or to find good schools for the kids may have been quite desirable. So it is not surprising that Panganiban assumed she had acquired dual citizenship and therefore cited the Cordero case in support of his analysis.
In fact two things appear to have been fueling this speculation. One is Poe mentioning that the oath of renunciation is all that is required for her to revert back to natural born citizenship based on Maquiling. Secondly, there is no mention of her in the news of having a Philippine passport except there was a new one or renewal issued to her in 2014. Not knowing of an existing Philippine Passport is hardly firm proof that Poe did not have one or that she was not a dual citizen entitled to one.
4. Chief Justice Panganiban and I would disagree on the basis that the concept of when and where domicile is established is independent of citizenship.
5. Disagree again because those facts are based on faulty news reports and contrary to facts already established.
6. Disagree again. There are copies of the notice from the IRS/Department of State confirming Poe being stripped of her US citizenship. The fact that it took more than a year is a testament to how slow bureacratic processes are i the US as they are in the Philippines.
I hope what I have share here is helpful in enlightening all the confusion surrounding this issue.
The Japzon case was quite clear. The person re acquired his Filipino citizenship, went back to the Philippines, and even got a CTC there. His residency was counted from there. If you have doubts, please read the case yourself, and do not depend on another. I’ll post the link at the bottom of my comment. I learned long ago that one should not always look to “experts” because they can be wrong. One must always look at the actual source, not just rely on the say-so of others.
http://www.lawphil.net/judjuris/juri2009/jan2009/gr_180088_2009.html
And lastly, there is still no information of how Grace Poe re-acquired her Filipino citizenship. This will be important, because if she used the wrong method, she will not have re-acquired it.
I am sorry but I respectfully disagree. I have read the case and the SC ruling therein and it is very clearly stated that in determining residency, the concept of domicile may be utilized which is not at all dependent on whether Poe was a citizen of the country of her primary domicile. The fact that in this case reacquisition of Filipino citizenship and a CTC was involved is not as important as the SC ruling that the concept of domicile can be used to determine and measure residency. Using the concept of domicile, Poe established her domicile in the Philippines in 2004/2005 when she set up a home and moved her kids schooling there which would give her the minimum 10 year presidential candidate requirement needed to run in 2016. Moreover, the only citizenship requirement that is relevant for Poe is that she was a natural born citizen at the time of filing a Certificate of Candidacy whether for Senate or Presidency which she fulfilled when she took the oath of renunciation priior to taking the MTCRB job in 2010. This is all pretty straight forward and if this was a legal exam, the answers have already been supplied along with explanations courtesy of Justice Panganiban. It cannot get much easier than that.
Sorry, but I am more inclined to use what the Supreme Court declared than what a retired Justice understands from the Supreme Court’s decision.
Please allow me to cite a direct excerpt from the case which you may not have seen in your rush to finish reading it:
“A domicile of origin is acquired by every person at birth. It is usually the place where the child’s parents reside and continues until the same is abandoned by acquisition of new domicile (domicile of choice). In Coquilla, the Court already acknowledged that for an individual to acquire American citizenship, he must establish residence in the USA. Since Ty himself admitted that he became a naturalized American citizen, then he must have necessarily abandoned the Municipality of General Macarthur, Eastern Samar, Philippines, as his domicile of origin; and transferred to the USA, as his domicile of choice.
As has already been previously discussed by this Court herein, Ty’s reacquisition of his Philippine citizenship under Republic Act No. 9225 had no automatic impact or effect on his residence/domicile. He could still retain his domicile in the USA, and he did not necessarily regain his domicile in the Municipality of General Macarthur, Eastern Samar, Philippines. Ty merely had the option to again establish his domicile in the Municipality of General Macarthur, Eastern Samar, Philippines, said place becoming his new domicile of choice. The length of his residence therein shall be determined from the time he made it his domicile of choice, and it shall not retroact to the time of his birth.
How then could it be established that Ty indeed established a new domicile in the Municipality of General Macarthur, Eastern Samar, Philippines?
xxx xxx
Ty’s intent to establish a new domicile of choice in the Municipality of General Macarthur, Eastern Samar, Philippines, became apparent when, immediately after reacquiring his Philippine citizenship on 2 October 2005, he applied for a Philippine passport indicating in his application that his residence in the Philippines was at A. Mabini St., Barangay 6, Poblacion, General Macarthur, Eastern Samar. For the years 2006 and 2007, Ty voluntarily submitted himself to the local tax jurisdiction of the Municipality of General Macarthur, Eastern Samar, by paying community tax and securing CTCs from the said municipality stating therein his address as A. Mabini St., Barangay 6, Poblacion, General Macarthur, Eastern Samar. Thereafter, Ty applied for and was registered as a voter on 17 July 2006 in Precinct 0013A, Barangay 6, Poblacion, General Macarthur, Eastern Samar.
In addition, Ty has also been bodily present in the Municipality of General Macarthur, Eastern Samar, Philippines, since his arrival on 4 May 2006, inarguably, just a little over a year prior to the 14 May 2007 local elections. Japzon maintains that Ty’s trips abroad during said period, i.e., to Bangkok, Thailand (from 14 to 18 July 2006), and to the USA (from 31 October 2006 to 19 January 2007), indicate that Ty had no intention to permanently reside in the Municipality of General Macarthur, Eastern Samar, Philippines. The COMELEC First Division and en banc, as well as this Court, however, view these trips differently. The fact that Ty did come back to the Municipality of General Macarthur, Eastern Samar, Philippines, after said trips, is a further manifestation of his animus manendi and animus revertendi.
xxx xxx
As this Court already found in the present case, Ty has proven by substantial evidence that he had established residence/domicile in the Municipality of General Macarthur, Eastern Samar, by 4 May 2006, a little over a year prior to the 14 May 2007 local elections, in which he ran as a candidate for the Office of the Mayor and in which he garnered the most number of votes.”
As you can read for yourself, the Supreme Court did not rule the way you understood the case.
And of course, the most important thing is lacking. In this case, it was proven that the candidate was a Filipino citizen. There is no proof yet that Grace Poe is a citizen, or if she has re-acquired Filipino citizenship.
I am sorry to say again that I have to disagree with you. In the case of Poe, we are not discussing domicile of origin. We are discussing the concept of establishing domicile which may or may not have anything to do with citizenship but has to do with showing via a preponderance of evidence that this intent was manifested. It is irrelevant if the specific facts of this case involving Ty differing from Poe with respect to being a local election or how he established intent of domicile by his becoming a citizen or getting a CTC. There is nothing is in the SC ruling with regard to Ty’s specific situation which says that citizenship is required to show intent to establish domicile.
To wit, this excerpt from the Japzon ponencia.
“As has already been previously discussed by this Court herein, Tys reacquisition of his Philippine citizenship under Republic Act No. 9225 had no automatic impact or effect on his residence/domicile. He could still retain his domicile in the USA, and he did not necessarily regain his domicile in theMunicipality of General Macarthur, Eastern Samar, Philippines. Ty merely had the option to again establish his domicile in the Municipality of General Macarthur, Eastern Samar, Philippines, said place becoming his new domicile of choice. The length of his residence therein shall be determined from the time he made it his domicile of choice, and it shall not retroact to the time of his birth.
There is nothing in the doctrine of jurisprudence that states that the specifics of the case cited has to be identical to the specifics of the situation that is being addressed. In this case, Japzon is being cited as a case supporting Poe’s meeting residency requirements because the SC ruled that establishment of domicile which may or may not involve citizenship is an alternative option to legal residency. By this standard, Poe can be shown to have established her domicile in the Philippines in 2004/2005 regardless of whether she was a Philippine citizen or not. I suggest you read up more on the jurisprudence concerning the use of the concept of domicile and its independence of citizenship status in election cases since you seem to have difficulty in understanding ot accepting this concept.
Failing that, I suggest you email Justice Panganiban since he is one of our most leading authorities on this matter
and you have a right to question his reasoning and conclusions which are diametrically opposed to yours save for some errors in facts that I have already pointed out.
You don’t have to agree with me. I’m only writing on how the Supreme Court ruled on the case. The case is clear. After one becomes a citizen, she could choose to establish a domicile again. But she had to be a citizen first. My suggestion is to read the Supreme Court ruling in entirety and not rely on a retired Justice. The ruling is the primary source of jurisprudence. A retired Justice is no longer part of the Supreme Court.
I think I already mentioned a couple of times I’ve read the case and believe me, I think I know how to read and analyze cases. And yes, so would a former chief justice of the Supreme Court whose opinion would be more authoritative and credible than your or my opinion. And yes believe it or not, the SC ruling in this case does clearly state that citizenship status is not required to establish domicile. That excerpt from the case ruling I included from my last post makes that point. The bottomline is Poe legally meets the residency requirement regardless of when she became a citizen, and it id for certain she is now a citizen as it had bern verified she carries a Philippine passport. Maybe we should just agree to disagree and leave it at that. Happy Trails!
We can’t agree to disagree. We follow the same law. We read the same jurisprudence. I’m sorry, but I did not offer my opinion. I wrote what the Supreme Court ruled. If that isn’t good enough for you, I don’t know what is.
“..as it had now been verified as of 2014…” and perhaps she hasvhad a Philippine passport since 2004 except it was not publicly known.
Now I fully understand. Thanks so much. Easy to understand.
After reading the exchanges, I am inclined to believe that Grace Poe is not qualified to run as President in 2016.
Atty. Dizon, but what if Poe re-entered Philippines as a resident alien? if my interpretation of Coquilla vs. COMELEC is correct, she may also re-establish residence even before reacquiring citizenship by becoming a resident alien. “The status of being an alien and a non-resident can be waived either separately, when one acquires the status of a resident alien before acquiring Philippine citizenship, or at the same time when one acquires Philippine citizenship. As an alien, an individual may obtain an immigrant visa under 13 of the Philippine Immigration Act of 1948 and an Immigrant Certificate of Residence (ICR) and thus waive his status as a non-resident.”
But if Poe re-entered Philippines as a non-resident alien, she could not have re-established Philippine domicile until she reacquired Filipino citizenship.
I also had that very question in mind before I wrote this article.
The Supreme Court declared that Philippine citizenship and residence is always lost when one chooses to be naturalized. Is residency gained by entering the country under a resident visa under section 13 of the Philippine Immigration Act? I have seen no case decided by the SC on this point. The statement in the Coquilla case is obiter dictum (the petitioner there did not enter the country using a section 13 visa – he entered under a balikbayan visa – it’s only for temporary residency). In any case, the reference in that case was only to emphasize that acquiring citizenship and acquiring residency are two separate things.
However, in the Coquilla case and some others, one will find that the form of residency for aliens is different from residency that counts for political purposes (sometimes, I wish they would just call it domicile so that there would be less confusion).
The paragraph before that one you cited stated this:
That’s also what I see in other cases. The SC counted residency for election purposes from the time one became a citizen, and depending on the fact of the case, would determine how the petitioner would establish residency, but only from the time he took his oath of citizenship.
Not correct. Grace Poe renounced her US citizenship when she was appointed MTRCB. This lawyer is spreading lies.
And then she used her US passport. How funny is that.
Read Japzon vs. Ty on residency.
Yes, it’s the basis for this article. Don’t read it piecemeal. Read everything, not just one paragraph.