Mod.

5: The Philippines as a State

@ilymarklee | CONSTI LAW I | SEM 01 | 2022

● A state within a State is contrary to the

Constitution as it recognized only one State– The
WHAT IS A STATE? Republic of the Philippines, nothing else. It
clearly runs counter to the national sovereignty
and territorial integrity of the Republic of the
Collector of Internal Revenue v. Rueda Philippines. (Province of North Cotabato v. GRP,
G.R. No. L-13250, 29 October 1971 GR NNo. 183591, 14 October 2008).

"It is a community of persons, more or less numerous,

permanently occupying a definite portion of territory,
independent of external control, and possessing a TERRITORY
government which a great body of inhabitant render
habitual obedience."
ARTICLE 1, 1987 Constitution:

"The stress is on its being a nation, (1) its people "The national territory comprises the Philippine
occupying, (2) definite territory, politically organized, archipelago, with all the islands and waters embraced
exercising by means of its (3) government its (4) therein and all other territories over which the
sovereign will over the individuals within it and philippines has sovereignty or jurisdiction, consisting of
maintaining its separate international personality. [It is] its terrestrial, fluvial, and aerial domains, including its
a territorial society divided into government and territorial sea, the seabed, the subsoil, the insular
subjects, claiming within its allotted area a supremacy shelves, and other submarine areas."
over all other institutions.

Territory: Terrestrial and Fluvial Domain

Definition and Elements of a State
Article 1, Montevideo Convention:
● The Philippines is an archipelago of over 7000
thousand islands. As such, its terrestrial domain
1. Defined Territory is governed by the Archipelagic Doctrine, which
2. Permanent Population of People treats as one several islands, and parts thereof,
3. Sovereignty and Capacity to Enter into Relations including interconnecting waters and other
with other States natural features which are closely interrelated to
4. Government form and intrinsic geographical, economic, and
political entity of which historically have been
regarded as such.
Case Study:
Province of North Cotabato v. GRP-Peace Panel, G.R.
No. 183591, 14 October 2008. Territory: Marital Domain

Q: Is Bangasamoro Juridical Entity a State? If yes, why? If ● Maritime is divided into several spheres and
no, why not? zones in accordance with international law. The
A: Bangsamoro Juridical Entity (BJE)= State within a State. Philippines, being a signatory to the United
Nation Convention on the Laws of the Sea
● The BJE is not merely an expanded version of the (UNCLOSE III), it subscribes to the following
ARMM but it is a State in view of the criteria set zones: (1) internal waters, (2) territorial sea, (3)
in Article 1, Montevideo Convention. It has its contiguous zones, (4) exclusive economic zone,
own definite territory under the MOA-AD, own and (5) high seas.
people, own government, and it has the capacity
to enter into relations with other states Q: How to determine these zones?
independent of the central government of the A: These zones are determined by first determining the
Philippines. starting point. In the Philippines, this is done through the
● The conclusion that it is a State bolstered by the Straight Baseline Method. (RA 9522- Straight Baseline
fact that its relationship with the central Method Act.)
government is that of "association", wherein two
states– usually, one weaker and one more
powerful State– enters into an agreement of
varying degrees of rights and obligations.
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

Straight Baseline Method: PEOPLE

1. Plots imaginary straight lines

PEOPLE AS A REQUIREMENT
2. Joining the Outermost points of the outermost
islands of the archipelago
Traditionally, it is opined that in order for people to be
3. Enclosing an area
an element of Statehood, it must be adequate for
4. Shall not depart to any appreciable extent to the
self-sufficiency and defense.
general configuration of the archipelago.
In 2020, the latest census, Philippines has a total
population of 109 Million.

DIFFERENT CONCEPTS OF "PEOPLE"

Under the Constitution, "people"are used in the following
senses:

1. Inhabitants (Section 2, Article III; Section 1,

Article XIII);
2. Electors (Section 4, Article VII); and
3. Citizens (Preamble; Article II; Section 7, Article
III)

IMPORTANCE OF CITIZENSHIP
By its nature, citizenship is the basis of conferring rights
on a person. Without which, a person will have– save for
fundamental human tights under international law– no
rights in a particular jurisdiction.

CITIZENSHIP

The Philippines enacted Republic Act No. 9225, which is

CITIZENSHIP
the enabling domestic law in drawing the straight
baselines enclosing the territory of the Philippines.
Tabasa v. Court of Appeals, G.R. No. 125793, 29 August
2006
NOTE: Straight Baseline Method is implemented through
R.A. No, 9522. It must be noted, however, that RA 9522
"Citizenship is a priceless possession…it is man's basic
merely implements the commitments of the Philippines in
right for it is nothing less than to have rights."
UNCLOS, which in turn, has nothing to do with the
acquisition or loss of territory. Meaning, even though the
Kalayaan Group of Islands are not within the territorial sea
ILLUSTRATIONS
and contiguous zone using the straight baseline method, the
Philippines has by no means waived its claim of sovereignty
★ Lee v. Director of Lands, G.R. No. 128195, 3
over them. (Magallona v. Ermita, G.R. No. 187167, 16
October, 2001
August 20110
★ Kilosbayan v. Gregory Ong, G.R. No. 177721,
3 July 2007.
★ In re: Ching, B.M. 914, 1 October 1999

RULES ON CITIZENSHIP

★ ACQUISITION , LOSS, & REACQUISITION

 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

MODES OF ACQUISITION
Q: What is the effect of the Australian citizenship laws
● By Birth which adhere to just soli to her Philippine Citizenship?
● By Naturalization A: NO EFFECT on her Philippine citizenship at all. The Court
says:
BY BIRTH
a. Rules on Acquisition of Citizenship by Birth (Jus "Thus, the herein private respondent, Rosaling Ybasco
Soli v. Jus Sanguinis) Lopez, is a Filipino citizen, having been born to a Filipino
b. Philippine Application: Jus Sanguinis or Jus Soli? father. The fact of her being born in Australia is not
c. Difficulty in Applying Jus Sanguinis tantamount to her losing her Philippine citizenship. If
Australia follows the principle of jus soli, then at most,
Jus Soli v. Jus Sanguinis private respondent can also claim Australian citizenship
a. Jus Soli- Law of the Soil resulting to her possession of dual citizenship."
b. Jus Sanguinis- Law of the Blood

Q: Which of the two is adhered to in the Philippines?

A: For a brief period, the concept of "jus soli" was applied in
the Philippines, upon a mistaken assumption that the rule–
being used in the US– is also extended to the Philippines.

Thus, in Roa v. Collector of Customs, and accompanying

cases, the principle of jus soli was applied by the courts.
However, those declared as citizens by the courts are
considered as citizens not because of jus soli but because of
The Philippine Application: Jus Sanguinis
res judicata (finality and unalterability of court decisions)
The rules on citizenship adhering to jus sanguinis can
formally be traced to the 1935 Constitution.
The matter was, however, put to rest upon adoption of 1935
Constitution which clearly shows that the Philippines
adheres to jus sanguinis and rejects jus soli. ARTICLE IV.-- CITIZENSHIP

SECTION 1. The following are citizens of the Philippines:

GO, Sr. v. Ramos
G.R. No. 167569, et. seq., 4 September 2009
(1) Those who are citizens of the Philippine
Islands at the time of the adoption of this
"The doctrine of jus soli was for a time the prevailing
Constitution
rule in the acquisition of one's citizenship. However, the
(2) Those born in the Philippine Islands of foregin
Supreme Court abandoned the principle of jus soli in the
parents who, before the adoption of this
case of Tan Chong v. Secretary of Labor. Since then, said
Constitution, had been elected to public
doctrine only benefited those who were individually
office in the Philippine Islands.
declared to be citizens of the Philippines by a final court
(3) Those whose fathers are citizens of the
decision on the mistaken application of jus soli."
Philippines.
(4) Those whose mothers are citizens of the
Philippines and, upon reaching the age of
CASE STUDY:
majority, elect Philippine citizenship.
Valles v. COMELEC
(5) Those who are naturalized in accordance with
G.R. No. 137000, 9 August 2000
law.
"The Philippine law on citizenship adheres to the
principle of jus sanguinis. Thereunder, a child follows the
nationality or citizenship of the parents regardless of the The Philippine Application: Jus Sanguinis
place of his/her birth, as opposed to the doctrine of jus
soli which determines nationality or citizenship on the Insofar as the jus sanguinis rule is concerned in the 1935
basis of place of birth." Constitution, there is, unfortunately, a difference in
treatment between a perosn whose father is a Filipino and a
person whose mother is a Filipino.
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

CASE STUDY:
Tecson v. COMELEC
G.R. No. 161434, 3 March 2004
(Jus Sanguinis- Father Edition)
FERNANDO POE JR.

Automatic Transmission of Citizenship if it is the father

who is the Filipino under the 1935 Constitution. .

Q: What about if the mother is Filipino?

A: There is no automatic transmission of citizenship. The
1935 Constitution clearly states that "those whose mothers
Q: Why was there a need for the Court to trace back the are citizens of the Philippines and, upon reaching the age of
citizenship of FPJ's grandfather? majority, elect Philippine citizenship"acquire Philippine
A: There was a need, because he was born 20 August 1939, citizenship.
under the 1935 Constitution, which states that a person is a
Filipino if his father is a Filipino. In turn, FPJ's father is a In other words, there is a need for an ELECTION OF
Filipino, only if FPJ's grandfather is a Filipino. PHILIPPINE CITIZENSHIP upon reaching the age of majority.

Q: "A child whose mother is a Filipino citizen is

automatically a Filipino. (1)
A: False with qualifications.

Case Study:
In re: Vicente D. Ching,
B.M. No. 914 (Resolution), 1 October 1999
(Jus Sanguinis- Mother Edition)

Q: What was the finding of the Court?

A: The Court considered all the available pieces of evidence
in the case. The death certificate of Lorenzo would indicate
that he died in 1954 at age 84, which means that he was
born sometime in 1870.

Moreover, he died in Pangasinan. In the absence of

evidence to the contrary, he is presumed to have stayed
there all his life.

As such, in 1890, Lorenzo would have benefitted from the

"en masse Filipinization" done under Philippine Bill 1902,
which provided that all inhabitant of the islands of the Q: Is Ching automatically Filipino?
Philippines who did not declare their intention of preserving A: No. As he is a child of an alien father and a FIlipino
their Spanish nationality between 11 April 1899 and 11 mother, there is no automatic transmission of citizenship.
October 1900 are considered Filipino, including their He must first elect Filipino citizenship in order to become a
children born after 11 April 1899. Filipino citizen. Pending election, he is an alien and his right
to be a Filipino citizen is still an inchoate right.

Note: The requirement of election is applicable only to

LEGITIMATE children of FIlipino women. Consequently, if a
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

child is ILLEGITIMATE, then he or she is not required to Exception: Under special circumstances, as when the minor
comply with the election requirements, because the child child of a Filipina mother and an alien father becomes a
automatically follows the citizenship of the mother. Filipino by virtue of the subsequent naturalization of the
alien father, informal acts of election such as participating in
electoral process, being a candidate for public office, are
Q: As a rule, how much time does the child have to
enough (Co v. Electoral Tribunal, G.R. No. 921191-92, 30 July
elect Filipino citizenship?
1991).
A: 3 years from reaching age of majority pursuant to
jurisprudence.

A child must elect to elect within a "reasonable time" after

attaining the age of majority. The Constitution does not
specify a specific time frame.

As a rule, however, "reasonable time" was construed to

mean 3 years after reaching the age of majority. The period
is based on the Opinion of the Secretary of Justice, as
adopted by the Supreme Court.

Q: Is the 3-year period absolute?

A: No. Q: In case the child is required to execute an Affidavit
of Election, what does he need to do afterwards?
A: Register the Affidavit with the nearest Local Civil
No. the period may be extended under certain Registrar.
circumstances, as when the person concerned has always
considered himself a Filiino or there are justifiable reasons
for the delay in electing. The child must register the affidavit with the proper Civil
Registrar. After registration, the child will take the oath of
Q: Was Ching able to elect Philippine Citizenship within a allegiance to the Republic of the Philippines.
"reasonable time?"
A: No. The span of 14 years that lapsed from the time he
reached the age of majority until he finally expressed his Case Study:
intention to elect Philippine citizenship is clearly way Cabiling, et al. v. Comm. Fernandez, Jr., et al.,
beyond the contemplation of the requirement of electing G.R. No. 183133, 26 July 2010
upon reaching the age of majority. Moreover, Ching has
offered no reason for the delay.

Q: Electing Filipino citizenship may be done through

informal but indicative acts.
A: True as an exception.

General Rule: Execute an Affidavit of Election (In re: Vicente

Ching)
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

NATURALIZATION

NATURALIZATION, Meaning

On the part of the State, it is the act of formally adopting

a foreigner into the political body of a nation by clothing
him or her with the privileges of a citizen. On the part of
the foreigner, it is a process by which he or she acquires
citizenship of another State voluntarily or by operation
of law.
Q: Is he allowed to complete his election of Philippine
citizenship?
A: Yes. In the case of Cabiling v. Fernandez, the Supreme
Q: Which of the following is not a mode of direct
Court said that, as long as the election is within the 3-year
naturalization?
period, the registration even beyond the said time frame
A: Constitutional
should be allowed IF IN THE MEANWHILE positive acts of
citizenship have been publicly, consistently, and
continuously done by the child. Besides, registration is just a
OUTLINE OF NATURALIZATION
formality to confirm the existence of fact.

"What we now say is that where, as in petitioners' case, the A. Direct

election of citizenship has in fact been done and a. Judicial Naturalization
documented within the constitutional and statutory b. Administrative Naturalization
timeframe, the registration of the documents of election c. Direct Act of Congress
beyond the frame should be allowed if in the meanwhile
positive acts of citizenship have publicly, consistently, and
continuously been done. The actual exercise of Philippine B. Derivative
citizenship for over half a century by the herein petitioner, is a. Derivative Naturalization of Minor
actual notice to the Philippine public which is equivalent to Children
formal registration of the election of Philippine citizenship." b. Derivative Naturalization of Spouses

IMPORTANT!
QUALIFICATIONS
The discrimination by the rules on citizenship was
abolished already in the 1973 and 1987 Constiution.
However, the abolition did not have a retroactive 1. Petitioner must be at least 21 years old
application, provisions as to election under 1935 2. Must have resided in the Philippines for at least
Constitution (born before 17 January 1973) were 10 years.
incorporated in the Constitution.
*Residence of 5 years may be sufficient if the foreigner has
established a new industry or introduced a useful invention
Q: Those who acquire citizenship by birth are in the Philippines, or married to a Filipino woman, or
considered natural-born citizens. worked as a teacher in the Philippines.
A: TRUE, Absolutely.
3. Of good moral character
4. Must have some known Lucrative Trade,
In summary, those who acquire citizenship by birth are Profession or Occupation
considered as NATURAL-BORN CITIZENS, as they acquire 5. Speaks and writes English or Spanish AND any
their citizenship without performing a positive act to principal languages of the Philippines; and
acquire or perfect their Philippine citizenship. Even those 6. If any, his or her minor children of school age are
who are still required to elect Philippine citizenship are enrolled in a school recognized by Government
considered as natural-born citizens by express provision of and teaching Philippine history, government and
the Constitution. civics.

In contrast, those who need to perform a positive act to

acquire citizenship are not natural-born citizens but
NATURALIZED CITIZENS.
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

school recognized by the GOvernment and

IMPORTANT!
teaching Philippine history, government, and
civics.
In the process of judicial naturalization the petitioner
5. Have a known trade or business or profession,
must show that he or she possesses ALL the
except if college degree holder but unable to
QUALIFICATIONS and that he or she possesses NONE of
practice profession because of citizenship;
the DISQUALIFICATIONS.
6. Able to speak Filipino, or any dialect in the
Philippines;
7. Have mingled with Filipinos and evince a sincere
PROCEDURE desire to learn and embrace the customs and
traditions and ideals of the Filipino people.

IMPORTANT!

Publication is a jurisdictional requirement. DIRECT ACT OF CONGRESS

Non-compliance is fatal for it impairs the very
jurisdiction of the court over the case. Whatever
proceedings conducted, the decision rendered and the Q: Derivative Naturalization automatically vests Filipino
oath of allegiance, are void for failure to comply with the citizenship on both minor children and spouse.
publication and posting requirements. (Republic v. dela A: False, the female spouse should prove that she
Rosa, G.R. No. 104654, 6 June 1994) suffers none of the disqualifications.

Q: Administrative Naturalization applies to all RULES ON DERIVATIVE NATURALIZATION

foreigners as an alternative to judicial naturalization Moya Lim Yao v. Commissioner, L-21289, 4 October 1971
A: False, absolutely.
The rules on derivative naturalization vary between the
minor child and the spouse.
ADMINISTRATIVE NATURALIZATION
For minor children, they are likewise naturalized if they
are dwelling in the Philippines at the time of the
Administrative Naturalization is governed by the provision naturalization of their parents. Those not dwelling in the
of Republic Act No. 9139. It applies only to aliens who were Philippines at the time of naturalization shall be
born and are residing in the Philippines. This is a distinct law considered naturalized only when they move to the
with limited application, that is, only those native-born Philippines while they are still minors. If they move to
aliens who have lived and resided in the Philippines all their the Philippines after having reached the age of majority,
lives. (So v. Republic, G.R. No. 170603, 29 January 2007) there is no more derivative naturalization.

QUALIFICATIONS: For spouses, only wives are granted the privilege of

derivative naturalization under Commonwealth Act No.
473. The law specified "a woman who is now or may
1. Petitioner must be born in the Philippines and hereafter be married to a citizen of the Philippines."
residing therein since birth.
2. Petitioner must be at least 18 years old at the Wives may be given the benefit of derivative
time of filing of petition. naturalization ipso facto upon the naturalization of their
3. Of good moral character. husbands, provided that she must not suffer from any of
4. Received primary and secondary education in a
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

4. By denaturalization or cancellation of certificate

the DISQUALIFICATIONS under the law. No need to prove
of naturalization
her qualifications.
5. By having been declared by competent as a
deserter of the Philippine armed forces in time
of war, unless granted plenary pardon or
Q: An alien later on naturalized as a Filipino must amnesty subsequently
return to his or her country of origin first and go back
as a citizen.
A: False, no need to go back and return. Naturalization By naturalization in or subscribing to an oath of
gives him or her the right to stay. allegiance of another country
BEFORE Republic Act No. 9225, which took effect on 17
September, 2003, naturalization in or subscribing to an oath
of allegiance will result into loss of citizenship.
DIRECT ACT OF CONGRESS
However, upon the effectivity of RA 9225, this will not
A naturalized alien– after having complied with all the anymore be a ground, as Filipinos who are naturalized in
requirements of law becomes entitled to all the rights that other countries are considered to have retained their
are accorded to a citizen including the right to stay in the Filipino citizenship.
country without restrictions.
"Express Renunciation"
Moya Lim Yao v. Commissioner of Immigration
It is a settled rule that renunciation must be expressly done.
G.R. No. L-21289, 4 October 1971
Renunciation cannot be found by implication or inference. It
must have been done distinctly and explicitly.
Consider, for example, precisely the case of the minor
children of an alien who is naturalized. It is indubitable
That means, holding an Australian passport and alien
that they become ipso facto citizens of the Philippines.
certificate of registration do not constitute effective
Could it be the law that before they can be allowed
renunciation. (Valles v. COMELEC). This is, however, different
permanent residence, they still have to be taken abroad
from the rule on eligibility to hold public office under RA
so that they may be processed to determine whether or
9225.
not they have a right to have permanent residence here?
The difficulties and hardships which such a requirement
entails and its seeming unreasonableness argue against Rendering service to or accepting commission from
such a rather absurd construction. armed forced of a foreign country,
As a rule, rendering such service will result into the loss of
LOSS citizenship EXCEPT if:
❖ It is with the consent of the Philippines
❖ The foreign country has a defensive or offensive
pact
Q: Which of the following is not a mode of losing
❖ The foreign country maintains forces in the
citizenship?
Philippines with the consent of the PH.
A: Rendering Service to a Foreign Army, in all cases.

EFFECT OF DENATURALIZATION TO DERIVATIVES

Citizenship may be lost: (Based on Commonwealth Act
If the ground is on the validity of the proceedings, the minor
No. 63 and 473)
children and wife are likewise denaturalized.

1. By naturalization in or subscribing to an oath of However, if the ground is personal to the denaturalized

allegiance of another country Filipino, the wife and children retain their Philippine
2. By express renunciation citizenship. (See Commonwealth Act No. 473)
3. Rendering service to or accepting commission
from armed forces of a foreign country, EXCEPT:
DESERTERS
a. It is with the consent of the PH
b. The foreign country has a defensive Deserters, as declared judicially, will also lose citizenship,
or offensive pacts unless they were pardoned or given amnesty, in which case,
c. The foreign country maintains forces they are automatically restore their citizenship.
in the Philippines with the consent of
the Philippines.
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

REACQUISITION IMPORTANT
(Frivaldo v. COMELEC)

The following are the recognized modes of reacquiring Repatriation takes effect only upon approval of the
citizenship: petition, but the effectivity retroacts to the date of
application.
1. Naturalization
2. Repatriation
3. Direct Act of Congress REACQUISITION UNDER RA 9225
4. Taking Oath of Allegiance under RA 9225 Lopez v. COMELEC

NATURALIZATION Reacquisition of citizenship under RA 9225 requires that the

former natural-born citizen to take an oath of allegiance to
A former citizen may re-acquire citizenship by the Philippines. Mere filing of a certificate of candidacy is
naturalization, provided that he or she has all the not sufficient.
qualifications and suffers none of the disqualifications.
For Persons with Dual Allegiance

For persons with dual allegiance, however, such as those

who have re-acquired Filipino citizenship under RA 9225,
REPATRIATION they must categorically renounce their foreign citizenship
and then take an oath of allegiance to the Philippines.
There are two laws that govern repatriation: PD 725 and
RA 8171. These are different laws and apply to different Note, however, that even though such persons have already
sets of people. renounced foreign citizenship, when they represent
themselves as foreigners (such as using passports)
PD 725 applies to former natural-born Filipinos who lost subsequently, they will voluntarily and effectively revert to
Filipino citizenship. PD 725 was not repealed by their status as person with dual allegiance. Another
President Aquino's Memorandum in 1986 and still renunciation and oath will be required for them to be
effective. (Frivaldo v. COMELEC) eligible to run for public office.

REPATRIATION GOVERNMENT
The second law, RA 8171, is more specific in application. It
applies only to:
1. Filipino women who lost their Philippine The Philippines as a State: Government
citizenship by marriage to aliens; and
2. Natural-born Filipinos including their minor
children who lost their PH citizenship on account US v. Dorr, G.R. No. 1051, 19 May 1903
of political or economic necessity.
The government is separate and distinct from the State.
Q: A natural-born Filipino who acquired citizenship by The government is the agent of the State, the principal,
repatriation is: through which the will of the State is formulated,
A: A natural-born Filipino because he or she is restored expressed, and realized. It is, in the abstract sense, the
to his or her own original status before losing Filipino existing political system, and in the concrete sense, the
citizenship. actual organisms of the organized system.

EFFECT OF REPATRIATION De Facto and De Jure Governments

(Bengzon III v. HRET, G.R. No. 142840, 7 May 2001)
❖ A de jure government is one which has legal
A repatriated natural-born Filipino is still considered as a basis in its existence and succession.
natural-born Filipino because the act of repatriation allows ❖ A de facto government is one which has no legal
the person to recover, or return to, his original status before source but only exercises governmental
he lost his Philippine citizenship. authority in fact. It may be one which:
➢ Usurps governmental power by force;
➢ Is established by the inhabitants of a
 Mod. 5: The Philippines as a State
@ilymarklee | CONSTI LAW I | SEM 01 | 2022

territory who rise in insurrections

against the parent state; and
➢ Is established by invading forces of an
enemy.

SOVEREIGNTY

The Philippines as a State: Sovereignty

Q: The concept of auto-limitation privides:

A: The sovereign cannot be limited by anyone and
anything except by itself

Change of Sovereignty

Sovereignty may change by annexation, cessasio, or some

other forms recognized under international law. In case of
change of sovereignty, political laws are abrogated (those
which regulate the relationship between the citizens and
the State) but all the other laws remain in force.