Title
IN RE: Patterson
Case
G.R. No. 536
Decision Date
Jan 23, 1902
The court upheld the Collector of Customs' authority to deport a British subject for refusing to take an oath of allegiance, affirming the State’s right to regulate foreign admission and maintain sovereignty.
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Case Digest (G.R. No. 536)

Facts:

  • Thomas Toye Patterson, a British subject, arrived in Manila on November 23, 1901, aboard the steamer Yuensang.
  • Patterson was a justice of the peace under the Australian Government and retained his official status despite residing in the U.S. for ten months prior.
  • He was arrested by Collector of Customs, Mr. W. Morgan Shuster, under Act 265, which allowed detention of individuals suspected of aiding insurrection against the U.S. or the Philippine government.
  • Patterson sought a writ of habeas corpus, arguing the Collector lacked reasonable grounds for his arrest.
  • The court permitted evidence regarding the law's application and the Collector's authority to be presented.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that the Collector of Customs had reasonable grounds to believe Patterson was guilty of the offenses specified in Act 265.
  • The court upheld the validity of Act 265, affirming it as a legitimate exercise of legislative power aimed at protecting public safety.
  • ...(Unlock)

Ratio:

  • The court's decision was based on the principle that states have the inherent right to protect their sovereignty and maintain public order.
  • Act 265 was viewed as a measure to prevent individuals posing a threat to public safety from entering the territory, rather than an immigration law.
  • The court emphasized the legislative body's authority to enact laws for state protection, with the executive branch, repre...continue reading

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