G.R. No. L-7474, March 25, 1912
HENRY ATHOLL EDWARDS, petitioner, vs. H. B. MCCOY, respondent.

FACTS

Henry Atholl Edwards, a British subject, sought entry into the Philippine Islands at the port of Manila. He was the son of a Chinese mother (full-blooded) and a Eurasian father (mixed European and Asiatic, with no Chinese blood). His father was a British subject, and his paternal grandparents were once U.S. citizens. Edwards was born and resided in the British concession of Amoy, China. The Board of Special Inquiry denied his entry, classifying him as a “Chinese person or person of Chinese descent” under U.S. immigration laws due to his Chinese maternal lineage. Edwards petitioned for a writ of habeas corpus, arguing his detention under a deportation order was illegal.

ISSUE

Whether the Board of Special Inquiry abused its discretion or authority in denying Edwards entry into the Philippines by classifying him as a person of Chinese descent based solely on his Chinese maternal ancestry, despite his paternal lineage and British nationality.

RULING

The Supreme Court denied the petition. The Court held that the decision of immigration authorities on an alien’s right to enter is final unless an abuse of authority is shown. Here, the Board’s decision was based on conceded factsEdwards’ Chinese motherand its conclusion that he was a person of Chinese descent was not devoid of foundation. The Court rejected the argument that race is determined solely by paternal lineage, noting that immigration matters involve executive and administrative discretion, not purely judicial principles. Since the Board deliberated on the evidence and its finding was not arbitrary, no abuse of discretion existed to warrant judicial review. The writ of habeas corpus was thus denied.