G.R. No. L-10788; October 28, 1915
VICENTE GÑILO, plaintiff-appellant, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellee.

FACTS:
Vicente Gñilo was charged with being a Chinese laborer in the Philippine Islands without the required certificate under the Chinese Exclusion Laws and the Act of Congress of February 20, 1907. He was arrested and subjected to administrative proceedings before the Bureau of Customs. Both the Board of Special Inquiry and, on appeal, the Insular Collector of Customs found that he had unlawfully entered and remained in the Philippines without authorization. Consequently, an order for his deportation was issued. Gñilo filed a petition for a writ of habeas corpus in the Court of First Instance of Manila, claiming he was born in the Philippines and was therefore a citizen. The court, after hearing, found no abuse of authority by the customs officials and denied the petition. Gñilo appealed to the Supreme Court.

ISSUE:
Whether the Insular Collector of Customs abused his discretion or authority in denying Vicente Gñilo the right to enter and remain in the Philippine Islands and ordering his deportation.

RULING:
The Supreme Court affirmed the decision of the lower court, holding that there was no abuse of discretion by the customs authorities. The Court reiterated that a Chinese person claiming birth in United States territory (which included the Philippines at the time) bears the burden of proving such citizenship by affirmative evidence. Mere testimony, even under oath, is insufficient to discharge this burden. The Collector of Customs’ findingsthat Gñilo was a Chinese alien not born in the Philippineswere supported by some evidence, and the refusal to believe Gñilo’s witnesses did not constitute an abuse of authority. Accordingly, the deportation order was upheld.