Conclusion

            From the foregoing, several conclusions may be drawn. First of which is the most basic: Citizenship is the structure which allows any legal system to work. It draws the boundaries between states and creates the legal border of who may be subjected to a state’s jurisdiction. It defines who may exercise civil and political rights within a given legal system. However, with the availability of naturalization as a means of acquiring citizenship the boundaries of jurisdictions is now becoming more obscure. The distinction between dual citizenship and dual allegiance allows a person to be a citizen of two countries. This challenges the concept of a state being defined by and confined within its citizens.

On the Philippine evolution of citizenship, it is safe to conclude that the country has adopted a more liberal stand on retaining or maintaining Philippine citizenship. This has been apparent in the classification of children of Filipino mothers who needed to elect citizenship as natural born, the retention of citizenship upon marriage to foreigners, and maintaining citizens who have dual citizenship as contrasted further to those with dual allegiance.

            It can also be concluded that as for naturalized individuals, citizenship is easily lost than acquired. This can be inferred from current jurisprudence which recognizes different means of implied renunciation by naturalized citizens and denies implied re-acquisition. This has been guided by the principle that citizenship is a privilege granted to individuals and not a right. Therefore, naturalized individuals must prove that they are worthy of the protection and benefits granted by the state. Naturalized citizens have the continuing burden to assert their good standing as citizens and avoid becoming liabilities to the granting State.

            However, as illustrated in the case of the Tecson v. COMELEC, the court still has to refine its procedures on how a person attains the status of a natural-born citizen. This is especially highlighted, when the country recognized as natural-born citizens those who were born before 17 January 1973, of Filipino mothers, who elect Philippine citizenship upon reaching the age of majority. Here, the court must provide distinct standards as to what kind of election is recognized and the reasonable time within one may elect his citizenship.

            Finally, on the issue of repatriation relative to the case of Bengzon, it can be concluded that the court through its power to interpret laws has committed judicial legislation. The law is clear as to who may be considered as natural-born citizens and this does not include former natural-born citizens who re-acquire their lost citizenship through repatriation. Given that this is the current jurisprudence, the court has the further duty to delineate the instances under which repatriation reverts a person to his original citizenship.