G.R. No. L-8017; March 11, 1913
Young Wampo vs. The Insular Collector of Customs

FACTS

Young Wampo, a Chinese person, arrived in Manila and was denied entry by a board of special inquiry, a decision affirmed by the Insular Collector of Customs. Instead of filing a petition for a writ of habeas corpus, Young Wampo filed a petition for a writ of certiorari in the Court of First Instance of Manila to review the Collector’s decision. The Collector demurred, arguing the court lacked jurisdiction. The lower court overruled the demurrer, heard the case on its merits, and annulled the Collector’s order. The Collector appealed.

ISSUE

Whether the Court of First Instance had jurisdiction to review the decision of the Insular Collector of Customs through a writ of certiorari.

RULING

No. The Supreme Court reversed the lower court’s judgment and affirmed the order of the Insular Collector of Customs. The writ of certiorari is only proper when an inferior tribunal has exceeded its jurisdiction and there is no plain, speedy, and adequate remedy. The Collector of Customs has jurisdiction to inquire into an alien immigrant’s right to enter. Furthermore, the remedy of habeas corpus, not certiorari, is the plain, speedy, and adequate remedy available to challenge an abuse of authority by the Collector in such immigration cases.