Title
De Leon vs. Insular Collector of Customs
Case
G.R. No. 39705
Decision Date
Oct 16, 1933
Yu Tian's inconsistent testimony led to deportation; customs authorities acted within legal discretion under Immigration Act of 1917.
Font Size:

Case Digest (G.R. No. 39705)

Facts:

  1. Landing Certificate Issued: On October 18, 1932, the Insular Collector of Customs issued a landing certificate in favor of Yu Tian, the appellant.
  2. Warrant of Arrest: On April 1, 1933, the respondent Collector of Customs issued an administrative warrant of arrest against Yu Tian, alleging that he gained admission to the Philippines through false and fraudulent representations, violating the Immigration Act of February 5, 1917.
  3. Investigation and Findings: On April 3, 1933, Yu Tian was brought before a board of special inquiry. The board found that he failed to prove his right to remain in the country and recommended deportation. The Insular Collector of Customs approved the recommendation.
  4. Habeas Corpus Petition: The appellant filed a petition for a writ of habeas corpus, which was denied by the Court of First Instance of Manila.

Key Details from Hearings:

  • During the October 17, 1932 hearing, Yu Tian provided detailed answers about his birth, family, and brothers.
  • During the April 3, 1933 hearing, Yu Tian gave inconsistent and evasive answers, including claiming he was born in the Philippines and later stating he did not know his birthplace. He refused to answer most questions about his family and background.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Legal Authority for Warrant: The warrant of arrest was authorized under Section 19 of the Immigration Act of February 5, 1917, and no sworn information was required for its issuance.
  2. Abuse of Discretion: The customs authorities acted within their discretion in ordering deportation, as Yu Tian’s inconsistent and evasive answers during the hearing provided sufficient grounds to conclude that he gained admission through false and fraudulent representations.
  3. Right to Remain Silent: The appellant’s argument that Yu Tian had a right to remain silent during the hearing was rejected, as such silence could be interpreted as an inability to prove his right to remain in the country.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.