G.R. No. L-22696 - Commissioner of Immigration vs. Ferdez

On June 7, 1961, Teban Caoili and his three brothers (Vicente, Santos, and Felipe) arrived from Hongkong aboard a CPA plane.
They were issued certificates of registration and identity by the Philippine Consulate General at Hongkong.
Their application for admission as Philippine citizens was docketed (IC Nos. 61-1881-C to 61-1884-C) and considered by the Bureau of Immigration Board of Special Inquiry No. 1.
On June 23, 1961, the Board of Special Inquiry rendered a decision admitting them as Filipino citizens by birth.
On July 7, 1961, the older Board of Commissioners (composed of Commissioner Galang and Deputy Commissioners de la Rosa and Talabis) affirmed the decision, with a majority vote favoring the admission.
Teban Caoili was subsequently issued Identification Certificate No. 15648 on July 10, 1961, which declared his admission as a Philippine citizen.
Following his admission, Teban exercised various rights of citizenship: he registered as a voter, was issued a Philippine Passport, paid his residence and income taxes, gained employment with Avesco, and became a member of the Social Security System.

On June 23, 1962, a new Board of Commissioners, replacing the old board due to a change of administration, conducted a motu proprio review under Sec. 27(b) of the Immigration Act of 1940 (as amended).
This new Board reversed the earlier decision of the Board of Special Inquiry, ordering the exclusion of Teban Caoili and his brothers as aliens not properly documented, pursuant to Sec. 29(a)(17) of the Act.
On the same date, the Commissioner of Immigration issued a Warrant of Exclusion commanding the immediate removal of the Caoili brothers to their port of origin or the country of which they were nationals.
An investigation by the Office of the Secretary of Justice ensued, wherein an investigator’s report (dated January 25, 1963) reaffirmed that Teban Caoili and his brothers were legitimate sons of Antonio Caoili—a Filipino citizen—despite conflicting testimonies regarding their origins.

More than one year after the issuance of the Warrant of Exclusion, on March 10, 1964, Teban Caoili was arrested by Capt. Delfin Macalinao and two CIS agents and detained at the CIS, PC compound, Camp Crame.
On March 13, 1964, a relative, Juan Garcia, filed a petition for Habeas Corpus on behalf of Teban, contending that his detention was illegal since he was a Filipino citizen.
The Commissioner of Immigration admitted the jurisdictional facts but claimed no knowledge sufficient to establish the illegality of the detention.
On March 14, 1964, Teban’s counsel moved for his provisional release on a cash bond of P500.00, although this motion faced opposition based on a prior case (Republic vs. Cloribel, L-20458).
On March 24, 1964, the lower court denied the motion for provisional release and rendered judgment based on stipulated facts, affirming the validity of the exclusion order and subsequent detention.
The case was then appealed to the Court of Appeals, where on April 7, 1964, that court ordered the release of Teban Caoili on bond.
The petitioner (Commissioner of Immigration) subsequently filed a petition for Certiorari and Prohibition with a preliminary injunction, challenging the Court of Appeals’ jurisdiction and the order of release.
After the oral argument and a brief minute resolution on May 15, 1964, the Supreme Court dismissed the petition without prejudice, upholding the decisions of the lower courts.

Whether the new Board of Commissioners had the statutory power, under Sec. 27(b) of the Immigration Act of 1940 (as amended), to review and reverse the decision of the Board of Special Inquiry and the prior Board of Commissioners.
Whether such a motu proprio review was within the legal framework or if it constituted an arbitrary overreach affecting established citizenship rights.

Whether the failure to notify Teban Caoili of the exclusion proceedings, given that he was not present during the motu proprio review, violated his right to due process.
Whether the absence of notice or an opportunity to be heard nullified the administrative decision to exclude him.

Whether the Court of Appeals possessed jurisdiction to entertain the appeal arising from a habeas corpus petition involving issues of citizenship and administrative exclusion.
Whether the issuance of the order of release on bond by the Court of Appeals was proper, given the alleged abuse of discretion in omitting prior notification procedures.