G.R. No. L-9793, December 29, 1958
Sy Chuan alias Lim Ah Tong, et al., petitioners-appellees, vs. Hon. Emilio Galang, et al., respondents-appellants.

FACTS

Petitioners, Chinese nationals, were subjects of deportation proceedings before the Board of Special Inquiry of the Bureau of Immigration. After several hearings, the investigation was declared terminated on August 3, 1954. Upon motion of the Alien Special Prosecutor, the Board issued an order reopening the probe to allow the complaining witness, Sim Siu Lan, to testify further on September 29, 1954. The petitioners objected, arguing the reopening was whimsical and would unduly delay the proceedings, as Sim Siu Lan’s prior declarations consisted of repeated retractions. The petitioners applied to the Manila court of first instance for a writ of prohibitory injunction. The court found the Board had exceeded its authority or abused its discretion in reopening the inquiry, noting Sim Siu Lan had executed denunciations, then an affidavit renouncing them, then testified against the petitioners, then retracted that testimony, and now sought to retract her retraction. The court prohibited the Board from considering evidence from the rehearing.

ISSUE

Whether the Board of Special Inquiry abused its discretion or exceeded its authority in reopening the deportation investigation.

RULING

The Supreme Court reversed the decision of the lower court. It held that the Board, as an administrative body engaged in administrative proceedings, possesses broad authority and discretion to seek the truth and gather evidence, and its processes need not conform strictly to judicial procedures. The Court found no abuse of discretion in the Board’s decision to reopen the investigation for the first time to hear the witness anew, potentially to clarify doubts, gather further details, or deduce connections to other aliens involved in prostitution. In the absence of such abuse, judicial interference was not warranted. The petition for injunction was denied.