G.R. No. 3537 22 January 1907

FACTS
– Ngo‑Ti filed a petition for a writ of habeas corpus on behalf of her minor son, Ngo‑Yuc, alleging illegal detention by the Insular Collector of Customs.
– The Collector asserted that Ngo‑Yuc was an alien Chinese immigrant barred from landing under Philippine immigration law and ordered his deportation.
– A board of special inquiry, convened by customs officials, found that Ngo‑Yuc had no right to land.
– The Court of First Instance ruled that the question of citizenship was not conclusive upon the immigration officers and, on the basis of evidence, ordered Ngo‑Yuc’s release, holding him a citizen of the Philippine Islands.
– The Attorney‑General appealed.

ISSUE
1. Whether the decision of immigration/customs officials on the citizenship (or right to remain) of a Chinese person is final and not subject to judicial review absent proof of abuse of discretion.
2. Whether the Collector of Customs possessed authority to enforce the Chinese immigration statutes, or such authority rested solely with the Secretary of Commerce and Labor or the Secretary of the Treasury.

RULING
– The Supreme Court held that, under the Act of 6 February 1905 and established U.S. precedent (e.g., United States v. Ju‑Toy, 198 U.S. 253; Pearson v. Williams, 202 U.S. 281), the administrative determination of citizenship or eligibility to enter the Islands is final when the officers have complied with procedural requirements and no abuse of authority is alleged.
– Judicial intervention is limited to cases where the immigration officer denies a hearing or otherwise acts abusively, which was not shown here.
– Consequently, the Court reversed the lower court’s judgment of release and ordered that Ngo‑Yuc be remanded to the custody of the Insular Collector. No costs were awarded; the judgment was to be entered after twenty days, and the case remanded for proper action.