Title
Abala vs. Insular Collector of Customs
Case
G.R. No. 40480
Decision Date
Mar 17, 1934
Gabino Abala, claiming Filipino citizenship via baptismal and admission certificates, was denied entry by customs authorities. Despite court appeals, the Supreme Court ruled he failed to sufficiently prove citizenship, upholding customs' discretion and rejecting certificates as conclusive evidence.
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Case Digest (G.R. No. 40480)

Facts:

  1. Return to the Philippines: Gabino Abala, the appellee, returned to the Philippines from China on June 18, 1931.
  2. Denial of Entry: The customs authorities denied him entry, claiming he was a Chinese citizen, despite his assertion that he was born in Cebu and possessed a baptismal certificate and a certificate of previous admissions into the Philippines.
  3. Investigation: The customs authorities conducted an investigation, giving Abala the opportunity to prove his right to remain in the country. However, they concluded that he failed to prove his Filipino citizenship, citing his inability to provide the names of his parents or any Filipino relatives until two years later.
  4. Second Investigation: A second investigation was conducted at Abala's request, but the Board of Special Inquiry of the Bureau of Customs again denied him entry. This decision was affirmed by the Insular Collector of Customs.
  5. Habeas Corpus Proceedings: Abala appealed to the trial court through habeas corpus proceedings. The trial court ruled in his favor, holding that the customs authorities abused their authority and discretion. The court relied on Abala's baptismal certificate and previous admission certificates as evidence of his right to remain in the Philippines.

Issue:

  1. Whether Gabino Abala sufficiently proved his Filipino citizenship to justify his right to remain in the Philippines.
  2. Whether the customs authorities abused their authority and discretion in denying Abala entry into the country.
  3. Whether certificates of previous admission and baptismal certificates constitute conclusive evidence of Filipino citizenship.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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