The Poe Cases: Preventing Statelessness for Foundlings in the Philippines implementation of rules and regulations in September 2022.36 As stated by Senator Grace Poe, co-author of the bill in the Senate, the passage of the act was a victory that ensured ‘abandoned children [would enjoy] equal treatment and every available service due [to] them’.37 The new law follows the path created by the Supreme Court in its decisions as it provides that foundlings found in the Philippines, and at Philippine embassies, consulates and territories are presumed to be natural-born citizens,38 which ensures that foundlings will not fade back to being ‘legally invisible’39 nor endure discrimination under the law due to their being foundlings. 36 37 38 39 approval-of-rules-and-regulations-for-foundling-law>, archived at <https://perma.cc/P6JJ645H>. Paolo Romero, ‘IRR for Foundlings Law Signed’, Philippine Star (online, 11 September 2022) <https://www.philstar.com/headlines/2022/09/11/2208822/irr-foundlings-law-signed>, archived at <https://perma.cc/VY2V-MLVA>. ibid. Foundling Recognition and Protection Act (n 22) s 5. Poe-Llamanzares v Commission on Elections (n 3). 315

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