G.R. No. 37105 December 9, 1933
GUI PENG HUI, in behalf of Gui Eng, petitioner-appellee, vs. THE ACTING INSULAR COLLECTOR OF CUSTOMS, respondent-appellant.

FACTS

Petitioner Gui Peng Hui, a resident Chinese merchant, sought the admission of Gui Eng as his minor son. The immigration authorities denied entry, finding Gui Eng was not a minor. The evidence before the Board of Special Inquiry included conflicting age assessments: three quarantine officers initially opined Gui Eng was over 21; Gui Eng and his father testified he was 22 upon arrival; and a later re-examination by one doctor, Dr. Pelican, certified he was under 21. The Board, based on its personal observation of Gui Eng’s physical appearance (developed muscles, forehead wrinkles, rough skin), concluded he was over 25. The Court of First Instance granted the writ of habeas corpus, setting aside the denial.

ISSUE

Whether the Court of First Instance erred in granting the writ of habeas corpus, thereby overturning the decision of the immigration authorities denying Gui Eng’s admission as a minor son of a resident Chinese merchant.

RULING

Yes, the lower court erred. The Supreme Court reversed the judgment and denied the writ. The findings of the Board of Special Inquiry are conclusive if supported by some evidence. Here, the Board’s conclusion that Gui Eng was not a minor was based on its personal observation and assessment of his physical characteristics, which constituted competent evidence. The conflicting medical opinion of Dr. Pelican, which contained no supporting factual basis, was insufficient to overturn the Board’s determination. The Court also noted the rule that in immigration cases, the credibility of witnesses and factual findings are primarily for the administrative authorities, and judicial review is limited to instances of no evidence, lack of fair hearing, or arbitrary disregard of facts—none of which were present.

AI Generated by Armztrong.