G.R. No. L-9853, December 4, 1914
CHUA YENG, petitioner-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, respondent-appellant.

FACTS:
On June 16, 1913, Chua Tan Ching, a person of Chinese race, arrived at the port of Manila from Amoy, China, and sought admission into the Philippine Islands as the legitimate minor son of Chua Yeng, a resident Chinese merchant in Manila. A board of special inquiry conducted hearings on June 17, June 25 (on rehearing), and March 5, 1914 (on second rehearing), each time denying his entry on the ground that the board did not believe him to be the legitimate son of Chua Yeng. The Insular Collector of Customs affirmed each decision. On March 14, 1914, Chua Yeng filed a petition for a writ of habeas corpus in the Court of First Instance of Manila. The lower court, without first determining whether the customs authorities had abused their authority, proceeded to take new testimony, found that Chua Tan Ching was indeed the legitimate minor son of Chua Yeng, and ordered his discharge from custody and admission into the Philippines. The Insular Collector of Customs appealed.

ISSUE:
Whether the Court of First Instance had jurisdiction to review the factual findings of the board of special inquiry and the Insular Collector of Customs regarding the right of a Chinese alien to enter the Philippines.

RULING:
No. The Supreme Court reversed the decision of the Court of First Instance. It reiterated the well-established doctrine that the determination of the right of a Chinese alien to enter the Philippines is vested primarily in the executive department (the customs authorities). The courts have no authority to intervene unless it is clearly shown that the customs authorities abused their discretion or acted in excess of their jurisdiction. An abuse of authority is not present merely because the court might have reached a different conclusion on the evidence; it exists only when there is no evidence at all to support the administrative decision. In this case, the board of special inquiry noted material conflicts in the testimonies of the alleged father, brother, and a relative, and found their stories contradictory and false in material points. This constituted sufficient evidence to support the board’s conclusion. Since there was some proof to support the denial of entry, there was no abuse of authority. Consequently, the Court of First Instance acted without jurisdiction in receiving new evidence and reversing the administrative decision. The Supreme Court ordered Chua Tan Ching remanded to the custody of the Insular Collector of Customs for execution of the decision of March 11, 1914.