G.R. No. L-8120, December 12, 1913
FERMIN DE LA CRUZ, petitioner-appellant, vs. THE INSULAR COLLECTOR OF CUSTOMS, respondent-appellee.

FACTS:
Fermin de la Cruz arrived in the Philippine Islands from China in December 1911. His right to land was examined by the Board of Special Inquiry of the Bureau of Customs. During the proceedings, witnesses initially testified that de la Cruz was born in Manila. However, in subsequent hearings, these same witnesses recanted their earlier statements, declaring that their prior testimony was false and had been given at the request of a Chinese individual who sought to secure de la Cruz’s entry. The Board of Special Inquiry found the witnesses’ testimony unreliable and concluded that de la Cruz had not overcome the presumption of being a Chinese alien, given his arrival from a Chinese port, his physical appearance, characteristics, and language. The customs authorities determined there was an attempt to fraudulently secure his entry through manufactured evidence. De la Cruz was consequently denied landing and detained. He then filed a petition for a writ of habeas corpus before the Court of First Instance, which dismissed the petition. He appealed the dismissal.

ISSUE:
Whether the Board of Special Inquiry committed a grave abuse of discretion or acted without jurisdiction in denying Fermin de la Cruz’s entry into the Philippines.

RULING:
The Supreme Court affirmed the judgment of the Court of First Instance, dismissing the petition for habeas corpus. The Court held that the Board of Special Inquiry did not abuse its authority or discretion. It acted within its legal powers in evaluating the evidence and concluding that the petitioner failed to rebut the presumption of being a Chinese alien. The Board’s finding that the testimony regarding de la Cruz’s birth in the Philippines was fabricated was a reasonable assessment of the evidence presented. Consequently, the detention by customs authorities was lawful. Costs were imposed on the appellant.