Facts:

This case involves two distinct petitions that arise from the actions taken by immigration authorities regarding Pedro Gatchalian. The first appeal, docketed as G.R. No. L-24844, is from the Court of First Instance of Manila (CFI) in Civil Case No. 61824, which involves a writ of habeas corpus filed by Macario Arocha on behalf of Gatchalian. The original facts state that on June 25, 1961, Pedro Gatchalian, a minor, arrived at the Manila International Airport, accompanied by family members, and sought entry as a Filipino citizen. Due to concerns regarding his documentation, immigration officials referred his case to a Special Board of Inquiry, which, after a hearing, declared Gatchalian a Filipino citizen on July 6, 1961. However, this decision was subsequently marked 'noted' by two Immigration Commissioners, while one voted against it, leading to complications.

The Secretary of Justice, in January 1962, ordered a review of cases where entry had been permitted based on cl

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Facts:

Arrival and Initial Proceedings

• On June 25, 1961, Pedro Gatchalian, a minor, arrived at Manila International Airport aboard a Cathay-Pacific Airways plane accompanied by four other persons (purportedly his father, an aunt, and two brothers) seeking entry as a Filipino citizen.
• Unsatisfied with his papers, an immigration officer referred his case to the Special Board of Inquiry.

Decision of the Special Board of Inquiry

• The Special Board of Inquiry held a hearing and rendered a decision on July 6, 1961, admitting Pedro Gatchalian and seven others as Filipino citizens (documented in I.C. Cases Nos. 61-2108-C to 61-2114-C).
• The individual members of the board recorded their actions, with Commissioners Talabis and De la Rosa merely marking the decision as “noted” on July 14 and 26, 1961 respectively, while Commissioner Galang dissented by voting to “exclude” on August 21, 1961.

Issuance of Documentation and Subsequent Review

• On August 16, 1961, following the Special Board’s decision, Pedro Gatchalian was issued Identification Certificate No. 16132 confirming his admission as a Filipino citizen.
• On January 24, 1962, the Secretary of Justice issued Memorandum Order No. 9, instructing Immigration Commissioners to review cases of entry allowed on the basis of claimed Filipino citizenship.

Action by the Immigration Commissioners

• In July 1962, allegedly after reviewing the entire proceedings before the Special Board of Inquiry, the Board of Commissioners reversed the earlier decision by ordering the exclusion of Pedro Gatchalian for improper documentation.
• Notably, the documents related to the decision and the subsequent warrant of exclusion bear the date July 6, 1962—although contention exists that the originally inscribed date was July 20, 1962, later altered to July 6 to bring the decision within the statutory one-year review period provided under Section 27(b) of Commonwealth Act 613, as amended by Republic Act 503.
• Pedro Gatchalian was taken into custody by immigration authorities on June 6, 1965.

Petition for Habeas Corpus

• On July 21, 1965, Macario Arocha, representing Pedro Gatchalian, petitioned the Court of First Instance of Manila for a writ of habeas corpus on behalf of a Filipino being unlawfully detained by the Immigration Commissioner.
• The respondents (immigration officials) defended the exclusion order citing the July 1962 decision of the Board of Commissioners; the central dispute focused on the actual date of the promulgated decision and whether the process of review afforded Pedro Gatchalian adequate opportunity to be heard.

Proceedings on Appeal and Certiorari

• After the lower court ordered Pedro Gatchalian’s immediate release following a ruling that the decision of the Special Board of Inquiry had become final, the immigration authorities appealed the decision (G. R. Nos. L-24844 and L-24853).
• The Immigration Commissioner also filed for certiorari and prohibition alleging grave abuse of discretion regarding the release order despite a pending appeal, contending that the proper procedural rules (including Section 20, Rule 41 of the Revised Rules of Court and Section 15, Revised Rule 102) were violated.

Issue:

Validity and Date of the Board of Commissioners’ Decision

• Whether the decision reversing the Special Board of Inquiry’s admission of Pedro Gatchalian was properly promulgated on July 6, 1962, or whether it had originally been dated July 20, 1962, thereby affecting its finality under the one-year review rule.
• Whether the alleged retyping and erasures on the official documents constitute evidence of malicious antedating in order to secure finality for the decision.

Procedural Due Process in the Review by the Board of Commissioners

• Whether Pedro Gatchalian was afforded the opportunity to be heard during the review or reversal process, particularly considering the statutory right to representation by counsel in appeal cases.
• Whether the manner in which the individual Immigration Commissioners “noted” or acted separately subverted the requirement for the board to deliberate collectively.

Jurisdiction and Appropriateness of the Habeas Corpus Release

• Whether the issuance of the writ of habeas corpus by the Court of First Instance, leading to the release of Pedro Gatchalian, was proper given the pending appeal by the Immigration Commissioner.
• Whether the release order constituted an excess of jurisdiction in violation of procedural rules (specifically Section 15, Revised Rule 102).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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