Facts:

The case of Ang Chay Tian vs. The Insular Collector of Customs revolves around the legal status of Ang Chay Tian, a Chinese national who was issued a landing certificate of residence on December 15, 1909, by the Insular Collector of Customs. This certificate was granted on the assertion that he was the minor son of Ang Song Tan, a resident Chinese merchant in the Philippines. At the time of issuance, Ang Chay Tian was approximately ten years old. Upon reaching the age of twenty-one, he was given a half interest in his father's business and continued to operate as a merchant in Manila. Following the death of his father, Ang Chay Tian became embroiled in legal disputes with his stepmother, who claimed that he was not a biological son but rather an adopted brother. This allegation prompted her to report him to immigration authorities, leading to the issuance of a warrant for his arrest. A board of special inquiry subsequently determined that Ang Chay Tian was not the legitim...

Facts:

1. Initial Admission and Claim:

   • On December 15, 1909, Ang Chay Tian was issued a landing certificate of residence by the Insular Collector of Customs.
   • He claimed to be the minor son of Ang Song Tan (or Ang Song Tin), a resident Chinese merchant in the Philippines.
   • At the time, Ang Chay Tian was about ten years old.

2. Business Involvement and Family Dispute:

   • When Ang Chay Tian turned twenty-one, his alleged father gave him a half interest in his business.
   • He subsequently became a merchant in Manila.
   • After his father’s death, a dispute arose with his stepmother, who reported to immigration authorities that Ang Chay Tian was not the son but an adopted brother of Ang Song Tan.

3. Arrest and Deportation Proceedings:

   • Based on the stepmother’s report, a warrant of arrest was issued.
   • The board of special inquiry concluded that Ang Chay Tian was not the minor son of Ang Song Tan in 1909 and recommended deportation.
   • The Insular Collector of Customs approved the recommendation.

4. Habeas Corpus Petition:

   • Ang Chay Tian filed a petition for a writ of habeas corpus in the Court of First Instance of Manila.
   • The court denied the writ but allowed him to file a petition to remain in the Philippines as a merchant.

5. Appeal by the Insular Collector of Customs:

   • The Insular Collector of Customs appealed, arguing that Ang Chay Tian should not be allowed to remain in the Philippines due to his alleged fraudulent entry in 1909.

6. Evidence of Merchant Status:

   • The records showed that Ang Chay Tian entered the Philippines in 1924 and 1933 as a bona fide merchant.

Issue:

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Ruling:

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Ratio:

1. Focus on Last Entry:

   • In deportation cases, the relevant inquiry is the individual’s last entry or conduct that constitutes grounds for deportation under the law.

2. Merchant Status as a Defense:

   • Ang Chay Tian’s status as a bona fide merchant during his entries in 1924 and 1933 entitled him to remain in the Philippines, regardless of any alleged fraud in 1909.

3. Limitation on Deportation:

   • The Court did not explicitly rule on the five-year limitation but emphasized that Ang Chay Tian’s merchant status during his last entries rendered him immune to deportation based on past misrepresentations.

4. Habeas Corpus as a Remedy:

   • The writ of habeas corpus is an appropriate remedy to challenge unlawful detention, and Ang Chay Tian’s detention was deemed unlawful under the circumstances.