G.R. No. L-9662; March 25, 1915

FACTS:
Lee Wing Seng, a 23-year-old man, was born in the Philippine Islands. During his minority, he had traveled to China and returned to the Philippines on one or two occasions, and was permitted to enter without question. On his last return from a temporary stay in China, the customs authorities refused him permission to land. The petitioner subsequently filed a writ of habeas corpus in the Court of First Instance of Manila. After reviewing the facts, the lower court found no abuse of authority by the customs authorities and affirmed the department’s decision. The petitioner appealed to the Supreme Court.

ISSUE:
Whether the courts can take jurisdiction to review the decision of the customs authorities when said authorities have misapplied the law to undisputed facts, specifically the petitioner’s status as a citizen born in the Philippine Islands.

RULING:
Yes. The Supreme Court reversed the decision of the lower court. While the courts generally will not take jurisdiction over alien immigration cases decided by the customs authorities unless an abuse of authority is shown, an exception exists when the authorities have misapplied the law to undisputed facts. In this case, the evidence conclusively established that Lee Wing Seng was born in the Philippine Islands, making him a citizen of the Philippines with a right to enter. Since there was no proof disputing this fact, the customs authorities misapplied the law. Therefore, the judgment was reversed, and the order of deportation was revoked. No costs were awarded.