Digest: Arnado v. Commission on Elections (767 SCRA 168, 2015)

Facts: Petitioner Arnado is a natural-born Filipino citizen who lost his Philippine citizenship after he was naturalized as citizen of the United States of America (USA). Subsequently, and in preparation for his plans to run for public office in the Philippines, Arnado applied for repatriation under Republic Act No. 9225 (RA 9225). He took an Oath of Allegiance to the Republic of the Philippines. an Order of Approval of Citizenship Retention and Re­ acquisition. rnado executed an Affidavit of Renunciation of his foreign citizenship.

Linog C. Balua (Balua), another mayoralty candidate, however, filed a petition to disqualify Arnado and/or to cancel his CoC on the ground, among others, that Arnado remained a US citizen because he continued to use his US passport for entry to and exit from the Philippines after executing aforesaid Affidavit of Renunciation.

Issue: Whether or not Arnado is disqualified because he continued to use his US passport.

Ruling: Yes. The use of a foreign passport amounts to repudiation or recantation of the oath of renunciation. Matters dealing with qualifications for public elective office must be strictly complied with. A candidate cannot simply be allowed to correct the deficiency in his qualification by submitting another oath of renunciation.