G.R. No. and Date: G.R. No. L-13283; January 23, 1918

FACTS:
Casimiro Bayani arrived in Manila on August 21, 1917, and sought entry into the Philippine Islands, claiming to be a citizen by birth. A board of special inquiry of the Bureau of Customs conducted a hearing and denied his request. This denial was affirmed by the Collector of Customs. Bayani subsequently filed a petition for a writ of habeas corpus in the Court of First Instance of Manila, which was denied, prompting this appeal. Bayani contended that the board of special inquiry did not accord him a full, free, and fair hearing. He alleged that the proceedings were characterized by leading and misleading questions, untrue statements intended to confuse witnesses, and a refusal to allow pertinent questions that would elucidate his right to enter. The Acting Attorney-General, representing the appellee, conceded that the appellant was not accorded such a hearing as required by law and recommended that the case be remanded for a new trial.

ISSUE:
Whether the board of special inquiry abused its discretion and authority by failing to accord the appellant a full, free, and fair hearing, thereby justifying judicial review and remand for a new hearing.

RULING:
Yes. The Supreme Court granted the appeal, reversed the judgment of the lower court, and ordered a new hearing before the board of special inquiry. The Court held that while hearings before immigration boards are summary, they are judicial in character. An alien seeking entry is entitled to a full, free, and fair hearing, which includes the right to be represented by counsel, to present witnesses, and to have pertinent questions asked to demonstrate his right to enter. The Court found that the board’s conduct, as shown by the record, was hostile and intimidating towards the witnesses (who were of humble origin and easily intimidated). The board made untrue statements and improperly barred a witness from testifying. This atmosphere of hostility rendered the board incapacitated from impartially weighing the evidence, constituting an abuse of discretion and a denial of due process. The Court emphasized that the essential requirement in such proceedings is an honest effort to ascertain the truth through methods fair and reasonable enough to constitute due process of law. The recommendation of the Attorney-General for a new hearing was therefore adopted.

Arellano, C.J., Torres, Carson, Araullo, Street, and Avanceña, JJ., concur.
Malcolm, J., filed a separate concurring opinion, agreeing on the abuse of discretion but reserving opinion on the specific rights of attorneys in such proceedings pending another case.

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