2022 Statelessness & Citizenship Review 4(2) was simulated, or that there was absence of a legal adoption process, or that there was inaction or delay in reporting, documenting, or registering a foundling.27 There are other indications of State concern for foundlings. President Duterte also signed the Domestic Administrative Adoption and Alternative Child Care Act of 2022,28 providing for alternative care, custody and adoption policies.29 Foundlings are among the abandoned children30 who may be adopted. This act adopts a similar definition of foundlings to that of the Foundling Recognition and Protection Act of 2022. Section 4(u) provides: [A] [f]oundling refers to a deserted or abandoned child of unknown parentage and whose date or circumstances of birth on Philippine territory are unknown and undocumented. This shall also include those with the above circumstances of birth during their infancy and/or childhood, and have reached the age of majority without benefitting from adoption procedures …31 CONCLUSION In the Poe cases, the Supreme Court chose to end ‘the plight of a defenseless class which suffers from a misfortune not of their own making’32 by holding that foundlings are natural-born citizens of the Philippines. Hence, they can no longer be treated as naturalised citizens of the Philippines, or worse, as stateless persons. With this finding, foundlings are, by constitutional interpretation, not barred from running for national offices or enjoying other rights of natural-born citizens. A contrary ruling from the Supreme Court in the Poe cases would have had adverse effects on thousands of foundlings, dooming them to statelessness and barring them from national public office. Notably, figures show that as of December 2021, there are at least 6,580 ‘certificates of foundling’ in the Philippines.33 There were also 1,473 foundlings who are legally available for adoption from 2009 to October 2021, according to the Department of Social Welfare and Development.34 Remarkably, the struggles of Senator Poe as a foundling and the decisions of the Supreme Court in the Poe cases were crucial in the creation and passage of the Foundling Recognition and Protection Act in May 202235 and the act’s 27 28 29 30 ibid s 5. Domestic Administrative Adoption and Alternative Child Care Act of 2022, Rep Act No 11642 (Philippines) (‘Domestic Administrative Adoption and Alternative Child Care Act’). ibid s 2(2). Section 4(a) of the Domestic Administrative Adoption and Alternative Child Care Act includes foundlings in its definition of ‘abandoned child’: Abandoned child refers to a child who has no proper parental care or guardianship, a foundling, or one who has been deserted by one’s parents for a period of at least three (3) continuous months, and has been declared as such by the NACC … 31 32 33 34 35 The NACC is the National Authority for Child Care. ibid s 4(u). Poe-Llamanzares v Commission on Elections (n 3). Christia Marie Ramos, ‘Senate Approves Bill for Foundlings’, Inquirer (online, 31 January 2022) <https://newsinfo.inquirer.net/1547860/fwd-senate-approves-bill-for-foundlings>, archived at <https://perma.cc/J2BZ-V5TH>. ibid. Hannah Torrezoga, ‘Hontiveros Hails Approval of Rules and Regulations for Foundling Law’, Manila Bulletin (online, 9 September 2022) <https://mb.com.ph/2022/09/09/hontiveros-hails- 314