G.R. No. L-6579, March 26, 1912
CHIENG AH SUI, plaintiff-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellant.

FACTS

Chieng Ah Soon, a Chinese merchant in Manila, returned from China with two boys, Chieng Ah Lui (20) and Chieng Ah Sui (16), claiming they were his sons. The Board of Special Inquiry initially admitted Ah Lui as Ah Soon’s son but denied entry to Ah Sui, finding he was not Ah Soon’s son. Ah Soon appealed to the Insular Collector of Customs, who affirmed the Board’s decision. Two more rehearings were granted, each resulting in the same denial, with the Collector affirming each time. A fourth rehearing was denied by the Collector, noting that three full hearings had already been conducted. Ah Soon then filed a petition for a writ of habeas corpus in the Court of First Instance, which granted the writ and ordered Ah Sui’s admission. The Collector appealed to the Supreme Court. A key piece of evidence was a prior declaration by Ah Soon filed with the Customs office, listing his family members, which did not include Ah Sui’s name.

ISSUE

Did the Insular Collector of Customs abuse his discretion in denying Chieng Ah Sui’s entry into the Philippines, based on the findings that Ah Sui was not Ah Soon’s son?

RULING

No. The Supreme Court reversed the lower court’s order and directed that Chieng Ah Sui be returned to the custody of the Insular Collector of Customs for deportation. The Court held that the Collector did not abuse his discretion. The Board of Special Inquiry properly considered Ah Soon’s prior declaration (which omitted Ah Sui) as part of the official records, and the multiple hearings provided Ah Soon ample opportunity to present evidence. The Court emphasized that the Collector’s findings of fact, when supported by evidence, are conclusive in habeas corpus proceedings absent a clear showing of abuse of authority. No such abuse was found here.