Title
IN RE: Patterson
Case
G.R. No. 536
Decision Date
Jan 23, 1902
A British official, Thomas Patterson, was detained in Manila under Act 265, a U.S. law targeting suspected insurrectionists. The court upheld his detention, ruling the Collector of Customs had discretionary authority to expel foreigners threatening public safety, affirming state self-preservation rights.
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Case Digest (G.R. No. 536)

Facts:

  1. Legislative Context: On October 15, 1901, Act 265 of the Legislative Commission of the Philippines was promulgated. This law aimed to prevent the entry of individuals suspected of aiding or instigating insurrection against the U.S. government in the Philippines.
  2. Petitioner's Arrival: Thomas Toye Patterson, a British subject and justice of the peace under the Australian Government, arrived in Manila on November 23, 1901, aboard the steamer Yuensang. He had previously resided in the U.S. for ten months before traveling to Hongkong and then to Manila.
  3. Arrest and Detention: Twenty-four hours after landing, Patterson was arrested by the Collector of Customs, W. Morgan Shuster, who claimed to have "reasonable grounds" to believe Patterson was guilty of offenses under Act 265.
  4. Habeas Corpus Petition: Patterson filed a writ of habeas corpus, challenging his detention. The court allowed extensive evidence and arguments on the legality of Act 265, the jurisdiction of the Collector of Customs, and the authority of the Legislative Commission to enact such a law.

Issue:

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Ruling:

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Ratio:

  1. State's Fundamental Rights: Every state has the inherent right to self-preservation, including the authority to regulate the entry and expulsion of foreigners to protect its sovereignty and public safety.
  2. Discretionary Executive Power: The executive branch, through administrative officers like the Collector of Customs, has discretionary authority to enforce laws aimed at preserving public order, and such decisions are not subject to judicial review unless expressly authorized by law.
  3. Act 265's Scope: Act 265 is a legitimate exercise of legislative power to address the abnormal conditions in the Philippines, targeting individuals suspected of aiding insurrection, regardless of nationality.
  4. Judicial Restraint: Courts must respect the discretionary powers of administrative officers in matters of public safety and national security, provided such powers are exercised within the bounds of the law.


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