G.R. No. 536 : January 23, 1902
In the matter of the application of THOMAS TOYE PATTERSON for a writ of habeas corpus.

FACTS:
On October 15, 1901, Act No. 265 of the Philippine Commission was promulgated. Thomas Toye Patterson, a British subject and a justice of the peace under the Australian Government, arrived at the port of Manila from Hong Kong aboard the steamer Yuensang on or about November 23, 1901. After an inspection on board, he was permitted to land. Twenty-four hours after landing, he was arrested by the Collector of Customs, W. Morgan Shuster, pursuant to Act No. 265. The Collector made a return to the writ of habeas corpus, stating that he had arrested Patterson because he had reasonable grounds to believe him guilty of offenses specified in the said law, which pertained to having aided, abetted, or instigated insurrection against the United States in the Philippines, or coming with such purpose. Patterson challenged his detention and deportation.

ISSUE:
Whether the Collector of Customs acted within his jurisdiction in arresting and ordering the deportation of Thomas Toye Patterson under Act No. 265, despite Patterson having already been permitted to land.

RULING:
The Supreme Court, through Chief Justice Arellano, denied the writ and upheld the authority of the Collector of Customs. The Court ruled that:
1. Act No. 265 is a political measure for self-preservation, not an immigration law. It is founded on the fundamental right of the State to its existence, integrity, and peaceable possession of its territory. Its specific object is to prevent the entrance of persons who have aided or instigated insurrection or who come with such intent, regardless of nationality.
2. The power conferred upon the Collector of Customs is discretionary and political in nature. The executive branch, to which the power of preservation of the State is especially entrusted, may exercise this sovereign attribute without judicial interference under the circumstances. The Collector’s determination, based on his “reasonable grounds to believe,” is conclusive and not subject to review by the courts regarding the sufficiency of evidence.
3. The fact of landing does not deprive the State of its right to deport. The Court analogized that permitting a prohibited person to land does not forfeit the State’s right to re-embark and deport him, just as a person with a contagious disease who lands in violation of quarantine laws may still be deported to prevent danger.
4. The treaty between England and the United States does not obligate the State to admit foreigners under all circumstances. International law recognizes the right of a State to set conditions for the entry of foreigners and to expel those who do not conform to local law, based on the supreme right of self-preservation.

Dissenting Opinion:
One Justice dissented, arguing that the power of the Collector under Act No. 265 was limited to preventing the landing of objectionable persons. Once Patterson passed the on-board inspection, was issued a permit, and landed without being in the charge of the inspecting officer, he was effectively “landed.” The law did not extend to arresting and deporting persons who had already legally landed. The dissenting view emphasized that such extraordinary discretionary power must be strictly confined to the statutory limits to prevent uncertainty and danger.