G.R. No. L-6157
W. CAMERON FORBES, J. E. HARDING, and C. R. TROWBRIDGE, plaintiffs, vs. CHUOCO TIACO (alias CHOA TEA) and A. S. CROSSFIELD, defendants.
July 30, 1910

FACTS:
Chuoco Tiaco (alias Choa Tea), a Chinese national, filed a complaint in the Court of First Instance (CFI) of Manila against W. Cameron Forbes (Governor-General of the Philippine Islands), J. E. Harding (Chief of Police), and C. R. Trowbridge (Chief of Secret Service). Chuoco Tiaco alleged that he was deported to Amoy, China, on August 19, 1909, under the orders of Governor-General Forbes, carried out by Harding and Trowbridge. Having returned to the Islands, he feared further deportation and sought a preliminary injunction to prevent it, along with P20,000 in damages.

Governor-General Forbes, Harding, and Trowbridge admitted the deportation but asserted it was done in the public interest, at the request of the Chinese Consul-General, and that Forbes acted in his official capacity as Governor-General, an act of the government itself, which he immediately reported to the Secretary of War.

Judge A. S. Crossfield of the CFI granted Chuoco Tiaco’s petition and issued the preliminary injunction against the Governor-General and his subordinates. Forbes et al. filed a demurrer and a motion to dissolve the injunction, arguing that the CFI lacked jurisdiction over such an act of the Governor-General. Judge Crossfield overruled the demurrer and disallowed the motion, letting the injunction stand.

Consequently, Forbes et al. initiated an original action for prohibition in the Supreme Court against Judge Crossfield, seeking to prevent him from continuing jurisdiction over Chuoco Tiaco’s case, arguing that the CFI lacked jurisdiction because the power to deport is a political act of the Governor-General.

ISSUE:
Can a Court of First Instance assume jurisdiction over a case seeking to enjoin the Governor-General and his subordinates from deporting an alien, and hold them liable for damages, when the act of deportation was performed by the Governor-General in his official capacity as a political act?

RULING:
The Supreme Court ruled that the Court of First Instance does not have jurisdiction to enjoin the Governor-General from performing an act within his official political capacity, nor to hold him liable for damages for such an act.

The Court held that the deportation of aliens, when ordered by the Governor-General in the public interest and reported to higher authorities (like the Secretary of War), constitutes a political act falling within his executive discretion. Such acts are not subject to judicial review or control by the courts under the principle of separation of powers. The Governor-General, when exercising his political powers, is accountable only to his sovereign (the President of the United States and the Secretary of War), not to the local courts. The decision of the executive in such political matters is conclusive.

Furthermore, the subordinate officers (Harding and Trowbridge) who carried out the deportation under the direct orders of the Governor-General were likewise not liable. Their acts were considered the acts of the chief executive, who himself was free from judicial responsibility for the political act.

Therefore, the Supreme Court granted the writ of prohibition, ordering Judge Crossfield to discontinue the trial of Chuoco Tiaco’s case, dissolved the injunction he had issued, and dismissed Chuoco Tiaco’s original complaint.