G.R. No. L-27030 March 6, 1968
PABLO GONZAGA, ANGEL GONZAGA, AMADOR GONZAGA and ANDRES GONZAGA, petitioners-appellees, vs. HON. MARTINIANO P. VIVO in his capacity as Commissioner of the Bureau of Immigration, respondent-appellant.

FACTS

Pablo, Angel, Amador, and Andres Gonzaga arrived in Manila on December 12, 1961, claiming to be Filipino citizens and children of Roman Gonzaga. The Board of Special Inquiry admitted them as Filipino citizens on December 18, 1961. However, on March 8, 1962, the Board of Commissioners, upon review, found they had not satisfactorily established their claim to Filipino citizenship and ordered their exclusion, issuing a warrant of arrest and exclusion. The Gonzagas filed a petition for prohibition with preliminary injunction in the Court of First Instance of Rizal to restrain the Commissioner of Immigration from arresting and deporting them. The lower court, after hearing and based on a stipulation of facts, found that the petitioners had sufficiently established their Filipino citizenship, granted the writ of prohibition, and made the preliminary injunction permanent. The Commissioner of Immigration appealed this decision.

ISSUE

Whether the Court of First Instance exceeded its powers in reviewing the factual findings of the Board of Commissioners regarding the petitioners’ claim to Filipino citizenship.

RULING

Yes, the Court of First Instance exceeded its powers. The Supreme Court reversed the lower court’s decision. The Supreme Court clarified that the action, though designated as prohibition, was in reality a review of the administrative decision of the Board of Commissioners. In such a review, the court’s function is limited to ascertaining whether the board’s findings are in accord with law, free from fraud or imposition, and have reasonable support in the evidence. The Board of Commissioners had found the evidence insufficient on two points: first, the documents presented to prove Roman Gonzaga’s citizenship contained conflicting birth dates, casting doubt on whether they referred to the same person; and second, aside from the self-serving testimonies of the applicants and their alleged father, no competent evidence was submitted to prove paternity and filiation. The Court of First Instance, however, ruled that the date discrepancies were immaterial and, based on a stipulation of facts stating the petitioners were children of Roman Gonzaga, concluded their citizenship was undisputed. The Supreme Court held that the lower court improperly resolved a factual issue based on evidence not presented before the administrative body and reversed its findings. Furthermore, the petitioners’ citizenship could not be properly stipulated upon after the Board of Commissioners had already ordered their exclusion for failure to establish it. Since the petitioners failed to prove their Philippine citizenship with sufficient and competent evidence before the Board, the lower court erred in granting the petition. The Supreme Court dismissed the petition for prohibition and dissolved the injunction.