G.R. No. L-11363; March 28, 1918
BERNARDO MOLDEN, plaintiff-appellant, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellee.

FACTS:
Bernardo Molden filed a petition for a writ of habeas corpus, alleging illegal detention by the Insular Collector of Customs. The Collector justified the detention with an administrative warrant issued under the Act of Congress of February 20, 1907, stating that Molden, a person of Chinese race, unlawfully entered the Philippine Islands on or about November 6, 1914. The warrant directed his apprehension and hearing before a board of special inquiry to show cause why he should not be deported.

Subsequent proceedings revealed that Molden’s initial admission was based on the recommendation of Gregorio Nieva, who later believed he had been defrauded into recommending Molden under the false pretense that Molden was a Filipino boy born in Mogpog. An investigation by a customs special examiner, Mygatt, included statements from witnesses in Mogpog, including the alleged mother, Benita Molden, and the real Bernardo Molden (also known as Alejandro), who all denied knowing the petitioner or recognizing his photographs. During his hearing, Molden admitted traveling under the name “Ng Lun.” The board of special inquiry and the Insular Collector of Customs, after reviewing the evidence, concluded Molden was a Chinese person who entered illegally and ordered his deportation.

The Court of First Instance remanded the case to the Collector for a fuller hearing. Molden appealed, assigning errors that the proceedings were void for lack of a precedent oath, that the court erred in not deciding the merits, and in remanding the case.

ISSUE:
Whether the Court of First Instance and, on appeal, the Supreme Court, can review and overturn the factual findings and deportation order of the Insular Collector of Customs based on the evidence presented in the administrative proceedings.

RULING:
The Supreme Court affirmed the deportation order. The Court ruled that:
1. Deportation proceedings are civil, not criminal. The administrative warrant for arrest and deportation issued by the Collector of Customs under the Act of Congress does not require a supporting oath.
2. The jurisdiction of courts in habeas corpus proceedings arising from deportation orders is limited. If the administrative department has found an alien to be unlawfully in the territory after a fair hearing, and there is any proof tending to sustain the charge, its decision is binding on the courts. Courts cannot reweigh the evidence or review its admissibility absent a showing of abuse of authority or error of law.
3. Examining the record, the Court found there was proof before the customs authorities to justify their conclusion. This included the investigator’s report (presented in the petitioner’s presence without objection) containing declarations from witnesses in Mogpog disclaiming knowledge of the petitioner, and the petitioner’s own admission of using a different name. The burden was on Molden to prove his lawful status, which he failed to do by not presenting countervailing evidence, such as calling his alleged parents.
4. Consequently, finding no abuse of authority, the Supreme Court modified the lower court’s judgment and upheld the deportation order.