Philippine nationality law details the conditions by which a person is a national of the Philippines. The two primary pieces of legislation governing these requirements are the 1987 Constitution of the Philippines and the 1939 Revised Naturalization Law. Any person born to at least one Filipino parent receives Philippine citizenship at birth. Foreign nationals may naturalize as Philippine citizens after meeting a minimum residence requirement (usually 10 years), acquiring real estate, demonstrating proficiency in either English or Spanish as well as a Philippine language, and fulfilling a good character requirement. The Philippines was previously a territory of the United States and local residents were non-citizen U.S. nationals in addition to their status as Philippine citizens. During American rule, any person born in the country automatically received Philippine citizenship by birth regardless of the nationalities of their parents. Since independence, citizenship is generally acquired only by descent from Filipino parents. The distinction between the meaning of the terms citizenship and nationality is not always clear in the English language and differs by country. Generally, nationality refers to a status given to an individual indicating the state which exercises jurisdiction over that particular person and is the common term used in international treaties when referring to members of a state; citizenship refers to the set of rights and duties a person has in that nation. When the Philippines was governed as a United States territory, Philippine citizens held non-citizen U.S. nationality. As American nationals, Filipinos were considered to owe allegiance to the U.S. and held some rights and protections from the federal government, but were excluded from political participation and could be treated as foreigners in some circumstances at the discretion of the United States Congress. In the modern post-independence Philippine context, there is no legal distinction between citizenship and nationality and the two terms are used interchangeably.