G.R. No. L-7096, December 12, 1912
ANG ENG CHONG, plaintiff-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellant.

FACTS

Ang Eng Chong, a 17-year-old Chinese boy, arrived in Manila with Ang Tiao Chuan (19), both claiming to be brothers and legitimate minor sons of Ang Co, a merchant in Manila. The Board of Special Inquiry found Ang Tiao Chuan to be the legitimate son of Ang Co and admitted him, but denied Ang Eng Chong’s entry, concluding he was not a legitimate son. The Collector of Customs affirmed the denial. Ang Eng Chong filed a petition for habeas corpus in the Court of First Instance (CFI) of Manila, which found an abuse of discretion by the customs authorities and ordered his admission. The Insular Collector of Customs appealed to the Supreme Court.

ISSUE

Whether the Court of First Instance erred in reviewing and reversing the decision of the customs authorities, specifically, whether there was an abuse of authority by the Board of Special Inquiry in denying Ang Eng Chong’s admission.

RULING

Yes, the CFI erred. The Supreme Court reversed the CFI’s decision and reinstated the denial of Ang Eng Chong’s admission.

The Court held that under established jurisprudence, the decision of immigration officers (like the Board of Special Inquiry) on the right of a Chinese person to land is final, unless there is an abuse of authority. Abuse of authority exists only in limited circumstances, such as: (a) denying admission to a person not belonging to any excluded class (e.g., a U.S. citizen); (b) failing to provide a full, fair, and free hearing; or (c) making a decision without any supporting evidence.

In this case, Ang Eng Chong belonged to an excluded class (Chinese aliens), and the record showed he was given a proper hearing. The Board’s decision was based on evidence, including material inconsistencies between the testimonies of the two alleged brothers regarding their home and occupations, and discrepancies between Ang Eng Chong’s statements and those of his alleged father. These contradictions provided sufficient ground for the Board to doubt his claim. Since there was evidence supporting the Board’s finding and no abuse of authority, the courts had no jurisdiction to overturn its decision. The CFI’s order was therefore reversed.