G.R. No. 188145 - Spouses Inalvez vs. Nool

The appellee, Gabino Abala, returned to the Philippines from China on June 18, 1931.
He presented a baptismal certificate and another certificate attesting that he had previously been permitted to land and enter the Islands.
He asserted his claim of being a native born in Cebu.

Upon his return, the customs authorities denied his right to enter the Philippines on the ground that he was a Chinese citizen.
A thorough investigation was conducted, during which the appellee was given full opportunity to prove his alleged Filipino birth and right to remain.
The investigation noted his failure to provide convincing evidence of his Filipino origin.

At the appellee’s request, a new investigation occurred approximately two years after the initial one.
The board of special inquiry of the Bureau of Customs reconfirmed the denial of his right to enter.
The decision of the board of special inquiry was subsequently affirmed by the Insular Collector of Customs, the appellant in the case.

The appellee did not prove he was a native of the Philippines.
It was significant that he only learned the names of his parents or any Filipino relatives after two years had elapsed.
Personal appearance and language: The board found that the appellee had all the hallmarks of being of pure Chinese ancestry, evidenced by his inability to speak any language other than Chinese.

The trial court, handling habeas corpus proceedings, set aside the customs authority’s decision, as it found the exercise of discretion by the customs authorities to be abusive.
Precedents such as Yu Pian v. Collector of Customs, Ong Liengco v. Collector of Customs, and Chua Go v. Collector of Customs were noted, which established that an issued certificate of residence or permission to land does not conclusively prove entitlement to remain if fraudulent means are later established.
Additional cases (e.g., Que Quay v. Collector of Customs, Jao Igco v. Morgan Shuster, Lee Jua v. Collector of Customs, and Chattamal v. Collector of Customs) were cited to underscore that the burden of proving entitlement to entry rests on the immigrant.

Whether the appellee satisfactorily proved his claim of being a native Filipino by establishing his birth in Cebu and Filipino parentage.
Whether the evidence provided (baptismal certificate and previous landing permit) was sufficient to overcome the presumption of non-native status.

Whether the issuance of certificates (allowing land entry) can be considered conclusive evidence of entitlement or if they are subject to reevaluation in light of later evidence.
Whether the existence of a certificate excuses the appellant from proving fraudulent entry or misrepresentation.

Whether the decision of the customs authorities, based on their investigation and evaluation of the appellee’s evidence, amounted to an abuse of discretion.
Whether the reversal rendered by the trial court in the habeas corpus proceedings was justified given the facts established by the board of special inquiry.