7/24/2019 Consti 1 Notes Midterm
1/28
I GENERAL CONSIDERATIONS
A. Political Law defined
Macariola v Asuncion
Political Law - a branch of public law which deals with the
organization and operation of the governmental organs of the
State and define the relations of the state with the inhabitants
of its territory.
the Code of Commerce partaes more of the nature of an
administrative law because it regulates the conduct of certain
public officers and employees with respect to engaging in
business! hence" political in essence.
Political Law embraces !
#. constitutional law$
%. law of public corporations$
&. administrative law$
'. law on public officers$ and
(. elections
Note :where there is change of sovereignty" the political lawsof the former sovereign" whether compatible or not with those of
the new sovereign" are automatically abrogated" unless they are
e)pressly re-enacted by affirmative act of the new sovereign.
B. Constitutional Law defined
*he true role of Constitutional Law is to effect an e+uilibrium
between authority and liberty so that rights are e)ercised within the
framewor of the law and the laws are enacted with due deference torights.,MMA v iron/
A due deference to the rights of the individual thus re+uires a more
careful formulation of solutions to societal problems.,MMA v iron /
A constitution is a system of fundamental laws for the governance
and administration of a nation. 0t is supreme" imperious"
absolute and unalterable e)cept by the authority from which it
emanates.
7/24/2019 Consti 1 Notes Midterm
2/28
0t has been defined as the fundamental and paramount law of the
nation.1#230t prescribes the permanent framewor of a system of
government" assigns to the different departments their respective
powers and duties" and establishes certain fi)ed principles on
which government is founded.,Manila Prince v 4S0S/
C. Constitution Defined Tyes!"inds
See reviewer
II BAC"GRO#ND O$ T%E &'() CONSTIT#TION
A. &'(* Edsa Re+! &'(* P,o+isiona,y Constitution
P,ocla-ation no. & $e/.012 &'(* 3P,o+isional Go+e,n-ent4- 5n the basis of the people6s mandate clearly manifested last
7ebruary 8" 0 and Salvador 9. Laurel are taing power in the name
and by the will of the 7ilipino people as President and ice
President" respectively.
-*he people e)pect a reorganization of government. Merit will be
rewarded. As a first step to restore public confidence 0 e)pect
all appointed public officials to submit their courtesy
resignations beginning with the members of the Supreme Court.
- *o help me run the government" 0 have issued :)ecutive 5rder
;o. #dated 7ebruary %(" # appointing ey cabinet ministers
and creating certain tas forces.
P,ocla-ation No. 5 6a,c7 012 &'(* 3P,o+isional Constitution48DECLARING A NATIONAL POLIC9 TO I6PLE6ENT RE$OR6S 6ANDATED B9 T%E PEOPLEPROTECTING T%EIR BASIC RIG%TS2 ADOPTING A PROISIONAL CONSTIT#TION2 ANDPROIDING $OR AN ORDERL9 TRANSITION TO A GOERN6ENT #NDER A NE; CONSTIT#TION.
- Adopts certain provisions of the #2/ days from date of thisProclamation" a Commission shall be appointed by the President
to draft a ;ew Constitution. *he Commission shall be composed
of not less than thirty ,&2/ nor more than fifty ,(2/ natural
born citizens of the Philippines" of recognized probity" nown
for their independence" nationalism and patriotism. *hey shall
http://sc.judiciary.gov.ph/jurisprudence/1997/feb1997/122156.htm#_edn10http://wp.me/p10moZ-q8Zhttp://wp.me/p10moZ-q8Zhttp://wp.me/p10moZ-q8Zhttp://wp.me/p10moZ-q8Zhttp://sc.judiciary.gov.ph/jurisprudence/1997/feb1997/122156.htm#_edn107/24/2019 Consti 1 Notes Midterm
3/28
be chosen by the President after consultation with various
sectors of society
Lawye, Lea@the legitimacy of the A+uino government is not a usticiable
matter. 0t belongs to the realm of politics where only thepeople of the Philippines are the udge. And the people have
made the udgment$ they have accepted the government of
President Corazon C. A+uino which is in effective control of
the entire country so that it is not merely a de facto
government but in fact and law a de ure government. Moreover"
the community of nations has recognized the legitimacy of tlie
present government. All the eleven members of this Court" as
reorganized" have sworn to uphold the fundamental law of the
Bepublic under her government.
B. ADOPTION AND E$$ECTIIT9 O$ T%E &'() CONSTIT#TION
-P,o+isional Constitution ART SECTION 1. *he ;ew Constitutionshall be presented by the Commission to the President who shall
fi) the date for the holding of a plebiscite. 0t shall become
valid and effective upon ratification by a maority of the votes
cast in such plebiscite which shall be held within a period of
si)ty ,>2/ days following its submission to the President.
&'() Constitution ART. ?III Sec 0)@*his constitution shall taeeffect immediately upon its ratification by a maority of the
votes cast in a plebiscite held for the purpose and shall
supersede all previous Constitutions.
P,ocla-ation no. 1( $e/. &&2 &'() - PB5CLA0M0;4 *9:BA*070CA*05; 57 *9: C5;S*0*D*05; 57 *9: B:PDEL0C 57 *9:
P90L0PP0;:S A5P*: EF *9: C5;S*0*D*05;AL C5MM0SS05; 57 #"
0;CLD0;4 *9: 5B0;A;C: APP:;: *9:B:*5.
De Leon + Es
7/24/2019 Consti 1 Notes Midterm
4/28
Article % of the Civil Code G Laws shall tae :ffect after #(
days following the completion of their publication in the
5fficial 4azette " unless otherwise provided. *his code,civil
code/ shall tae effect one year after publication.
Ci+il Code 3RA NO. 5(*signed Hune #= #. ocuments or classes of documents as the President of the
Philippies shall determine from time to time to have general
applicability and legal effect$
8. Charter of a city$
7/24/2019 Consti 1 Notes Midterm
5/28
=. Circulars issued by the Monetary Eoard G they are meant to
fill in the details of the Central Ean Act which that body is
supposed to enforce.
Need not /e u/lis7ed: 3/ut2 s7ould /e su/-itted to t7e #.P.
Law Cente,4
#. presidential issuances which apply only to particular
persons or class of persons such as administrative and
e)ecutive orders need not be published on the assumption
that they have been circularized to all concerned.
%. 0nterpretative regulations and those merely internal innature" that is" regulating only the personnel of the
Administrative agency and not the public.
&. Letters of 0nstruction issued by the administrative
superiors concerning rule or guidelines to be followed by
their subordinates in the performance of their duties.
'. Local ordinances
0f the law provides a period longer or shorter than the #( days"
then such longer or shorter period" as the case maybe" shall
prevail.
0f the law says provides that it will tae effect immediately" it
means that it shall tae effect immediately after publication
with the #( day period being dispensed with.
7/24/2019 Consti 1 Notes Midterm
6/28
T7e clea, o/@ectof the above-+uoted provision is to give thegeneral public ade+uate notice of the various laws which are to
regulate their actions and conduct as citizens. ?ithout such
notice and publication" there would be no basis for the
application of the ma)im Iignorantia legis non e)cusat.I 0t would
be the height of inustice to punish or otherwise burden acitizen for the transgression of a law of which he had no notice
whatsoever" not even a constructive one. ,*anada v *uvera/
II #DICIAL ELABORATION O$ T%E CONSTIT#TION
A. Const,uction on Su,e-acy
A constitution is a system of fundamental laws for the governance
and administration of a nation. 0t is supreme" imperious"
absolute and unalterable e)cept by the authority from which it
emanates.
0t has been defined as the fundamental and paramount law of the
nation.1#230t prescribes the permanent framewor of a system of
government" assigns to the different departments their respective
powers and duties" and establishes certain fi)ed principles onwhich government is founded. ,Manila Prince v 4S0S/
*he fundamental conception in other words is that it is a supreme
law to which all other laws must conform and in accordance with
which all private rights must be determined and all public
authority administered.1##3
Dnder the doctrine of constitutional supremacy" if a law or
contract violates any norm of the constitution that law or
contract whether promulgated by the legislative or by the
e)ecutive branch or entered into by private persons for privatepurposes is null and void and without any force and
effect. *hus" since the Constitution is the fundamental"
paramount and supreme law of the nation" it is deemed written in
every statute and contract., Manila Prince v 4S0S/
in case of doubt" the Constitution should be considered self8eecutin< rather than non8self8eecutin
7/24/2019 Consti 1 Notes Midterm
7/28
Dnless the contrary is clearly intended" the provisions of the
Constitution should be considered self-e)ecuting" as a contrary
rule would give the legislature discretion to determine when" or
whether" they shall be effective. *hese provisions would be
subordinated to the will of the lawmaing body" which could mae
them entirely meaningless by simply refusing to pass the needed
implementing statute.1#(3
0n self-e)ecuting constitutional provisions" the legislature may
still enact legislation to facilitate the e)ercise of powers
directly granted by the constitution. ,Manila Prince v 4S0S/
Decla,ation of P,inciles Not Self8eecutin'(% are
cognizant of the compelling State interest to ensure orderly and
credible elections by e)cising impediments thereto" such as
nuisance candidacies that distract and detract from the larger
http://sc.judiciary.gov.ph/jurisprudence/1997/may1997/118295.htm#_edn43http://sc.judiciary.gov.ph/jurisprudence/1997/may1997/118295.htm#_edn44http://sc.judiciary.gov.ph/jurisprudence/1997/may1997/118295.htm#_edn43http://sc.judiciary.gov.ph/jurisprudence/1997/may1997/118295.htm#_edn447/24/2019 Consti 1 Notes Midterm
9/28
purpose. *he C5M:L:C is mandated by the Constitution with the
administration of elections#>and endowed with considerable
latitude in adopting means and methods that will ensure the
promotion of free" orderly and honest elections.#8Moreover" the
Constitution guarantees that only bona fide candidates for public
office shall be free from any form of harassment and
discrimination.#=*he determination of bonafide candidates is
governed by the statutes" and the concept" to our mind is"
satisfactorily defined in the 5mnibus :lection Code. ,Pamatong v
C5M:L:C/
,?hat is recognized in Section %>" Article 00 of the Constitution
is merely a privilege subect to limitations imposed by law. 0t
neither bestows such a right nor elevates the privilege to the
level of an enforceable right. *here is nothing in the plain
language of the provision which suggests such a thrust or
ustifies an interpretation of the sort./
As a general rule" the provisions of the Constitution are
considered self-e)ecuting" and do not re+uire future legislation
for their enforcement. 7or if they are not treated as self-
e)ecuting" the mandate of the fundamental law can be easily
nullified by the inaction of Congress.1#=3 %owe+e,2 someprovisions have already been categorically declared by this Court
as non self-e)ecuting. ,*ondo v CA/
*hese provisions" which merely lay down a general principle" are
distinguished from other constitutional provisions as non self-
e)ecuting and" therefore" cannot give rise to a cause of action
in the courts$ they do not embody udicially enforceable
constitutional rights.1%%3,*ondo v CA/
they are mere statements of principles and policies. As such"
they are mere directives addressed to the e)ecutive and the
legislative departments. 0f unheeded" the remedy will not lie
with the courts$ but rather" the electorate6s displeasure may be
manifested in their votes.,*ondo v CA/
note ! ,#/ Fou cant bring a case base on non self-e)ecuting
provisions of the constitution. ,%/ Fou must loo for a
provisions of the constitution which is self-e)ecuting or a law
that interprets or implements it.
B.T%E DOCTRINE O$ SEPARATION O$ PO;ERS AND T%ET%EOR9 O$ #DICIAL REIE;
http://sc.judiciary.gov.ph/jurisprudence/2007/july2007/167324.htm#_ftn18http://sc.judiciary.gov.ph/jurisprudence/2007/july2007/167324.htm#_ftn22http://sc.judiciary.gov.ph/jurisprudence/2007/july2007/167324.htm#_ftn18http://sc.judiciary.gov.ph/jurisprudence/2007/july2007/167324.htm#_ftn227/24/2019 Consti 1 Notes Midterm
10/28
0t is a fundamental principle flowing from the doctrine of
separation of powers that Congress may not delegate its
legislative power to the two other branches of the government"
subect to the e)ception that local governments may over local
affairs participate in its e)ercise. ?hat cannot be delegated is
the authority under the Constitution to mae laws and to alter
and repeal them$ the test is the completeness of the statute in
all its term and provisions when it leaves the hands of the
legislature.
*o determine whether or not there is an undue delegation of
legislative power" the in+uiry must be directed to the scope and
definiteness of the measure enacted. The legislature does not
abdicate its functions when it describes what job must be done,
who is to do it, and what is the scope of his authority.
(Soriano v Laguardia mtrcb)
*he lawmaing body cannot possibly provide for all the details in
the enforcement of a particular statute.1>
7/24/2019 Consti 1 Notes Midterm
11/28
constitutional agencies might leave much to be desired in given
instances" is inherent in the perfection of human institutions.
,angara v electoral tribunal/
,a/ *hat the government established by the Constitution followsfundamentally the theory of separation of power into the
legislative" the e)ecutive and the udicial.
,b/ *hat the system of checs and balances and the overlapping of
functions and duties often maes difficult the delimitation of
the powers granted.
,c/ *hat in cases of conflict between the several departments and
among the agencies thereof" the udiciary" with the Supreme Court
as the final arbiter" is the only constitutional mechanism
devised finally to resolve the conflict and allocate
constitutional boundaries.
,d/ *hat udicial supremacy is but the power of udicial review
in actual and appropriate cases and controversies" and is the
power and duty to see that no one branch or agency of the
government transcends the Constitution" which is the source of
all authority. ,angara v electoral tribunal/
PRES#6PTION O$ CONSTIT#TIONALIT9
Eefore a statute or its provisions duly challenged are voided" an
une+uivocal breach of" or a clear conflict with the Constitution"
not merely a doubtful or argumentative one" must be demonstrated
in such a manner as to leave no doubt in the mind of the Court.
0n other words" the grounds for nullity must be beyond reasonable
doubt. ,4arcia v rilon/
courts must assume that the legislature is ever conscious of the
borders and edges of its plenary powers" and passed laws with
full nowledge of the facts and for the purpose of promoting what
is right and advancing the welfare of the maority.,4arcia v
rilon/
CONDITIONS $OR T%E E?ERCISE O$ #DICIAL REIE;
0t is hornboo doctrine that the e)ercise of the power of
udicial review re+uires the concurrence of the following
re+uisites" namely!
7/24/2019 Consti 1 Notes Midterm
12/28
,#/ the e)istence of an appropriate case$
,%/ an interest personal and substantial by the party raising the
constitutional +uestion$
,&/ the plea that the function be e)ercised at the earliestopportunity$ and
,'/ the necessity that the constitutional +uestion be passed upon
in order to decide the case ,auto v romulo/
:ven with the presence of an actual case or controversy" the
Court may refuse to e)ercise udicial review unless the
constitutional +uestion is brought before it by a party having
the re+uisite standing to challenge it. Le
7/24/2019 Consti 1 Notes Midterm
13/28
,e=ui,e-ents /efo,e a liti
7/24/2019 Consti 1 Notes Midterm
14/28
The Court will decide cases, otherwise moot, if: first, there is a grave violation of theConstitution; second, the exceptional character of the situation and the paramountpublic interest is involved; third, when the constitutional issue raised requiresformulation of controlling principles to guide the bench, the bar, and the public; andfourth, the case is capable of repetition yet evading review.1!
"The gist of the question of standing is whether a party alleges such personal sta#e inthe outcome of the controversy as to assure that concrete adverseness which sharpensthe presentation of issues upon which the court depends for illumination of difficultconstitutional questions. $nless a person is in%uriously affected in any of hisconstitutional rights by the operation of statute or ordinance, he has no standing."1&'
(etitioners have come before the Court in their respective capacities as citi)en*taxpayers and accordingly, assert that they "dutifully contribute to the coffers of the+ational Treasury."1&Clearly, as taxpayers, they possess the requisite standing toquestion the validity of the existing "(or# -arrel ystem" under which the taxes they pay
have been and continue to be utili)ed. /t is undeniable that petitioners, as taxpayers, arebound to suffer from the unconstitutional usage of public funds, if the Court so rules./nvariably, taxpayers have been allowed to sue where there is a claim that public fundsare illegally disbursed or that public money is being deflected to any improper purpose,or that public funds are wasted through the enforcement of an invalid or unconstitutionallaw,1&0as in these cases.
oreover, as citi)ens, petitioners have equally fulfilled the standing requirement giventhat the issues they have raised may be classified as matters "of transcendentalimportance, of overreaching significance to society, or of paramount publicinterest."1&2The Co3 Chairperson4s statement during the 5ral 3rguments that the
present controversy involves "not merely a systems failure" but a "complete brea#downof controls"1&!amplifies, in addition to the matters above*discussed, the seriousness ofthe issues involved herein. /ndeed, of greater import than the damage caused by theillegal expenditure of public funds is the mortal wound inflicted upon the fundamentallaw by the enforcement of an invalid statute. 1'63ll told, petitioners have sufficient locusstandi to file the instant cases.
FUNA VS CSSExemptions locus standithe Court has time and again acted liberally on the locus standirequirements
and has accorded certain individuals, not otherise directly in!ured, or ithmaterial interest a"ected, by a #overnment act, standing to sue provided aconstitutional issue of critical signicance is at stake.$he ruleonlocus standiis a%ter all a mere procedural technicality in relation to hichthe Court, in a catenao% cases involving a subject of transcendentalimport, has aived, or relaxed, thus alloing non&traditional plainti"s, suchas concerned citi'ens, taxpayers, voters or legislators, to sue in the publicinterest, albeit they may not have been personally in!ured by the operation
http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt129http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt145http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt146http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt147http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt148http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt149http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt150http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt129http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt145http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt146http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt147http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt148http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt149http://www.lawphil.net/judjuris/juri2013/nov2013/gr_208566_2013.html#fnt1507/24/2019 Consti 1 Notes Midterm
15/28
o% a la or any other government act( )n David, the Court laid out the bareminimum norm be%ore the so&called *non&traditional suitors+ may beextended standing to sueexemptions mootnessNonetheless, this Court has exercised its poer o% !udicial revie in cases otherise
rendered moot and academic by supervening events on the basis o% certainrecogni'ed exceptions, namely -./ there is a grave violation o% the Constitution0 -1/the case involves a situation o% exceptional character and is o% paramount publicinterest0 -2/ the constitutional issue raised requires the %ormulation o% controllingprinciples to guide the 3ench, the 3ar and the public0 and -4/ the case is capable o%repetition yet evading revie(15
ANA67)N VS E8EC
Grounds for Transcedental importance
(1) the public character of the funds or other assets involved in the case,
(2) the presence of a clear case of disregard of a constitutional orstatutory prohibition by the public respondent agency or instrumentality
of government, and
(3) the lack of any other party with a more direct and specific interest in
raising the questions being raised.
AKBAYAN VS AQUINO
Locus standi
)n a petition anchored upon the right o% the people to in%ormation on matterso% public concern, hich is a public right by its very nature, petitioners neednot sho that they have any legal or special interest in the result, it beingsu9cient to sho that they are citi'ens and, there%ore, part o% the generalpublic hich possesses the right(.:
Public concern or public interest
it is for the courts to determine on a case by case basis whether the matter at issue
is of interest or importance, as it relates to or affects the public.21!"
Estarija vs RanadaGovenciong vs CaShould be raised in the earliest opportunity
.:;2?(1:.?4.(
7/24/2019 Consti 1 Notes Midterm
16/28
we held that the earliest opportunity to raise a constitutional issue is to raise it in
the pleadings before a competent court that can resolve the same, such that, if it
was not raised in the pleadings before a competent court, it cannot be considered at
the trial, and, if not considered in the trial, it cannot be considered on appeal.
$#NCTIONS O$ #DICIAL REIE;
#. for the guidance of and as a restraint upon the future.,*o
educate/. ,Havier v Comelec/
%. to determine and declare the constitutionality of the law .
&. Dnder the doctrine of chec and balance "to determine whether
another branch of the government has ept within
constitutional limits.
All cou,ts can ee,cise t7e Powe, of udicialRe+iew
w7ile lowe, cou,ts s7ould o/se,+e a /eco-in< -odesty in ea-inin G September =" #=
BA ;5.
7/24/2019 Consti 1 Notes Midterm
23/28
subsoil, the insular shelves, and other submarine areas The watersaround, between, and connecting the islands of the archipelago,regardless of their breadth and dimensions, form part of the internalwaters of the Philippines"
$or purposes of %n%lysis& Philippine n%tion%l territory includes thefollo'in(#
)%* the Philippine %rchipel%(o& 'ith %ll the isl%nds %nd '%ters e+,r%ced
therein-),* %ll other territories o"er 'hich the Philippines h%s so"erei(nty or
.urisdiction consistin( of territori%l& flu"i%l %nd %eri%l do+%ins-)c* the territori%l se%& the se%,ed& the su,soil& %nd insul%r shel"es %nd othersu,+%rine %re%s- and)d* the '%ters %round& ,et'een& %nd connectin( the isl%nds of the%rchipel%(o& re(%rdless of their ,re%dth %nd di+ensions!
7/24/2019 Consti 1 Notes Midterm
24/28
photo courtesy of http!madeandistaffugmacidimagesm#$P%
Territorial seais th%t p%rt of the se% e/tendin( 10 n%utic%l +iles )19 +s*fro+ the lo'2'%ter +%r! It is %lso c%lled the +%r(in%l se%& the +%r(in%l
,elt or the +%rine ,elt!&eabedis the l%nd th%t holds the se%& lyin( ,eyond the se%shore& includin(+iner%l %nd n%tur%l resources! It is %t the top portion of the su,+%rine%re%!The subsoilis e"erythin( ,ene%th the surf%ce soil %nd the se%,ed includin(+iner%l %nd n%tur%l resources!
'nsural shelves%re the su,+er(ed portions of % continent or offshoreisl%nd& 'hich slope (ently se%'%rd fro+ the lo' '%terline to % point 'here
% su,st%nti%l ,re% in (r%de occurs& %t 'hich point the ,otto+ slopesse%'%rd %t % consider%,le incre%se in slope until the (re%t oce%n depths %rere%ched- %nd
(ther submarine areasrefers to those 'hich %re under the territori%l se%!They %re otther'ise referred to %s se%+ount& trou(h& trench& deep& ,%n&sho%l& %nd reef!
Two 7und,ed 6ile Ecusi+e Econo-ic one
P ;5. #(
7/24/2019 Consti 1 Notes Midterm
25/28
t7e constitutional ,o7i/ition a
7/24/2019 Consti 1 Notes Midterm
26/28
,esided in t7e P7iliine Islands2 and t7ei, c7ild,en /o,nsu/se=uent t7e,eto2 s7all /e dee-ed and 7eld to /e citi>ens oft7e P7iliine Islands and as suc7 entitled to t7e ,otection oft7e #nited States2 ecet suc7 as s7all 7a+e elected to ,ese,+et7ei, alle
7/24/2019 Consti 1 Notes Midterm
27/28
citi>ens7i /y t7ose nati+es of t7e P7iliine Islands w7o do notco-e wit7in t7e fo,eens of t7e #nited States2o, w7o could /eco-e citi>ens of t7e #nited States unde, t7e lawsof t7e #nited States2 if ,esidin< t7e,ein.
Dnder the Hones Law" a native-born inhabitant of the
Philippines was deemed to be a citizen of the Philippines as of
## April #=en of so-e ot7e, count,y.
APRIL && &(''8 #L9 &2 &'0 us soli
&'51 Constitution ,atified on 6ay &H2 &'51brought to
an end to any such lin with common law"/y adotinens7i 8
Section #" Article 000" #ens of t7e P7iliines.
,'/ *hose whose mothers are citizens of the Philippines and upon
reaching the age of maority" elect Philippine citizenship.
,(/ *hose who are naturalized in accordance with law.
7/24/2019 Consti 1 Notes Midterm
28/28