G.R. No. L-1455 : October 29, 1903
In The Matter of the application of FRANK STANLEY ALLEN for writ of habeas corpus.

FACTS:
Frank Stanley Allen, an alien, filed a petition for a writ of habeas corpus. He was detained by the Collector of Customs for the Philippine Archipelago, W. Morgan Shuster, who threatened to deport him on the ground that he was a prohibited alien contract laborer under the U.S. Act of Congress of March 3, 1903, regulating immigration. The petitioner did not contest his classification as a prohibited alien at this stage. Instead, he challenged the Collector of Customs’ authority to enforce the deportation provisions of the said Act. Allen argued that the Act, by its terms, placed the administration of immigration laws under the U.S. Secretary of the Treasury and the Commissioner-General of Immigration. Since the Collector of Customs had not been authorized by either of these officials or by a specific act of Congress to execute the law, his detention and threatened deportation were unlawful.

ISSUE:
Has the Collector of Customs for the Philippine Archipelago lawful authority to execute the provisions of the U.S. Immigration Act of March 3, 1903, pertaining to the detention and deportation of prohibited aliens?

RULING:
YES. The Supreme Court denied the writ of habeas corpus, upholding the Collector of Customs’ authority.
The Court ruled that the Act of March 3, 1903, was largely a reenactment and compilation of prior U.S. immigration laws. Prior to this Act, immigration laws in the Philippines were administered by the military government under the President’s authority as Commander-in-Chief, exercised through the Secretary of War. Specifically, War Department Circular No. 13 (April 14, 1899) and subsequent regulations declared U.S. immigration laws in effect in the Philippines and directed collectors of customs to enforce them. This administrative framework was already operational when the 1903 Act was passed.
The Court applied the doctrine from Cross vs. Harrison, which held that in newly acquired territory, existing officers may continue to administer the laws until new civil authorities are appointed and installed by the proper political department. Consequently, the Collector of Customs, who was lawfully enforcing immigration laws before the 1903 Act, retained the authority to administer the new Act until the U.S. Treasury Department, through the Commissioner-General of Immigration, established its own machinery in the Islands. The Act’s extension of the term “United States” to include the Philippines did not automatically divest the incumbent officers of their authority. Therefore, the Collector of Customs acted within his lawful power in detaining and proceeding to deport the petitioner.