Title
Calacday vs. Vivo
Case
G.R. No. L-26681
Decision Date
May 29, 1970
Petitioners sought to halt deportation, claiming final citizenship rulings. Lower court issued injunction, but Supreme Court ruled it lacked jurisdiction over pending administrative proceedings, emphasizing constitutional protections and judicial compliance.
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Case Digest (G.R. No. L-26681)

Facts:

  1. Parties Involved:

    • Petitioners: Jose Calacday, Pedro Calacday, Juan Calacday, Julio Calacday, Manuel Calacday, Marcelo Calacday, and Benito Calacday.
    • Respondents: Martiniano P. Vivo (Acting Commissioner of Immigration), the Board of Commissioners of the Bureau of Immigration, and the Deportation Officer of the Bureau of Immigration.
  2. Nature of the Case:

    • The petitioners filed a prohibition proceeding in the Court of First Instance of Manila on May 14, 1965, seeking to enjoin the respondents from taking them into custody, conducting deportation proceedings, or canceling their identification certificates.
  3. Background:

    • The petitioners claimed that previous decisions by the Board of Inquiry and the Board of Immigration Commissioners, which declared them Filipino citizens, had become final and conclusive. They argued that the respondents had no authority to deport them under the Philippine Immigration Act of 1940, as amended.
  4. Lower Court Decision:

    • The lower court ruled in favor of the petitioners on September 19, 1966, finding that the respondents had abused their authority or lacked jurisdiction. The court issued a permanent injunction, prohibiting the respondents from arresting or deporting the petitioners.
  5. Appeal:

    • The respondents appealed the lower court's decision, arguing that the court lacked jurisdiction to intervene in the deportation proceedings, which were still pending before the Board of Commissioners.
  6. Supreme Court Reference:

    • The Supreme Court referenced its earlier decision in Vivo v. Montesa, which held that the lower court had no jurisdiction to interfere with deportation proceedings before the Board of Commissioners had rendered a final decision.

Issue:

  1. Whether the lower court had jurisdiction to issue a writ of prohibition and injunction against the respondents, given that the deportation proceedings were still pending before the Board of Commissioners.
  2. Whether the lower court complied with the constitutional requirement to clearly and distinctly state the facts and the law in its decision.
  3. Whether the issuance of warrants of arrest by the Commissioners of Immigration, solely for investigation purposes and before a final deportation order, violated the constitutional right against unreasonable searches and seizures.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Disposition

  • The Supreme Court reversed and set aside the lower court's order of September 19, 1966, and denied the writ of prohibition prayed for by the petitioners. No costs were awarded.


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