G.R. No. 12690; September 27, 1917

FACTS:
The defendant-appellant, Lim Bin, was born in Manila in July 1882 to Chinese parents. At age five or six, he went with his parents to China. He returned to Manila in 1898 with the intention of making the Philippines his permanent home and continuously resided there thereafter. Lim Bin considered himself a citizen of the Philippines by virtue of his birth. He failed to register as a Chinese laborer under the provisions of Act No. 702 (the Chinese registration law). The government initiated deportation proceedings against him for this failure. At the time Act No. 702 took effect (March 27, 1903) and throughout the registration period, Lim Bin was a minor, not reaching the age of majority until July 1905. The government presented no evidence to contradict these facts, and the Attorney-General renounced the right to file a brief.

ISSUE:
Whether a person born in the Philippine Islands to Chinese parents, who returned and established residence before the American sovereignty, and who was a minor during the entire registration period prescribed by Act No. 702, can be deported as a Chinese laborer for failure to register under said Act.

RULING:
No. The Supreme Court reversed the lower court’s judgment, dismissed the complaint, and ordered the appellant’s release.

The Court held that Lim Bin was not required to register under Act No. 702. The ruling was based on two primary grounds:
1. Status as a Citizen/Non-Alien: The appellant, having been born in the Philippines and having adopted it as his home prior to the American acquisition, was not considered an alien subject to the registration law. The spirit of American law, particularly the principle of jus soli (citizenship by birth) embodied in the Fourteenth Amendment to the U.S. Constitution as interpreted in U.S. vs. Wong Kim Ark, guided this conclusion. The Court found it was not the intention of Congress or the Philippine Legislature to require such individuals to register.
2. Minority Status: Independently, the Court also held that it was not the legislative intent to require minors to register under Act No. 702. Since Lim Bin was a minor throughout the entire registration period, he was exempt from the registration requirement.

Consequently, his failure to register did not provide a legal basis for his deportation. The separate concurring opinion of Justice Malcolm provided an alternative legal rationale under Spanish law, concluding that Lim Bin was a citizen of the Philippine Islands and therefore outside the scope of the Chinese exclusion and registration laws.

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