Facts:

The case of Bernardo Molden vs. The Insular Collector of Customs arose from a petition for a writ of habeas corpus filed by the plaintiff, Bernardo Molden, on April 17, 1915, in the Court of First Instance of Manila. Molden claimed he was being unlawfully detained by the defendant, the Insular Collector of Customs. The defendant countered that Molden, a person of Chinese descent, had unlawfully entered the Philippine Islands on November 6, 1914, in violation of the Act of Congress of February 20, 1907. An administrative warrant (No. 160) was issued for his arrest, which stated that Molden and his alleged brother, Faustino Molden, were not entitled to admission into the Philippines as they were not natives.

On July 26, 1915, Molden submitted a supplementary petition alleging that the Bureau of Customs had conducted investigations without notifying him, which he claimed violated his rights. The defendant admitted to conducting investigations and stated that a board of spec...

Facts:

1. Initial Detention and Petition for Habeas Corpus:

   • On April 17, 1915, Bernardo Molden filed a petition for a writ of habeas corpus in the Court of First Instance of Manila, alleging illegal detention by the Insular Collector of Customs.
   • The defendant, the Insular Collector of Customs, responded that Molden was a Chinese person who entered the Philippines unlawfully on November 6, 1914, in violation of the Act of Congress of February 20, 1907.

2. Administrative Warrant:

   • Molden was detained under Administrative Warrant No. 160, issued on April 15, 1915, which accused him of being a Chinese person not entitled to admission into the Philippines.
   • The warrant alleged that Molden and his alleged brother, Faustino Molden, entered the Philippines unlawfully and remained in violation of the law.

3. Supplementary Petition and Investigation:

   • On July 26, 1915, Molden filed a supplementary petition, claiming that the Bureau of Customs conducted secret investigations without notice.
   • The defendant admitted to conducting investigations and presenting evidence, including witness testimonies, before the Board of Special Inquiry.
   • The Board concluded that Molden was illegally in the Philippines and recommended deportation.

4. Key Findings from Investigations:

   • Molden claimed to be the son of a Filipina woman born in Mogpog, Marinduque.
   • Immigration Inspector Mygatt investigated in Mogpog and found that the real Bernardo Molden was still living there and had never been to China.
   • Witnesses, including Molden’s alleged mother, denied that the detained Molden was her son.
   • Molden admitted to using the name "Ng Lun" during his travel, casting doubt on his identity.

5. Court Proceedings:

   • The Court of First Instance remanded the case to the Insular Collector of Customs for further proceedings.
   • Molden appealed, assigning errors related to the lack of a precedent oath, the court’s refusal to rule on the merits, and the remand of the case.

Issue:

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Ruling:

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Ratio:

1. Nature of Deportation Proceedings:

   • Deportation proceedings are civil, not criminal, and do not require the same procedural safeguards as criminal cases.
   • Administrative warrants for deportation need not be issued under oath.

2. Binding Authority of Administrative Decisions:

   • The findings of administrative authorities, such as the Insular Collector of Customs, are binding on the courts if supported by any evidence, even if slight.
   • Courts cannot interfere with administrative decisions unless there is clear abuse of authority.

3. Burden of Proof on the Alien:

   • The burden of proving lawful entry and identity lies with the alien.
   • Molden failed to provide sufficient evidence to disprove the findings of the immigration authorities.

4. Fair Hearing Requirement:

   • While the hearing need not be formal, it must provide the alien with an opportunity to present evidence and cross-examine witnesses.
   • Molden was given such an opportunity but chose to rely on technicalities rather than substantive proof.