G.R. No. L-10280 - Qua Chee Gan vs. The Deportation Board

On May 12, 1952, Special Prosecutor Emilio L. Galang filed deportation charges against petitioners (Qua Chee Gan et al.) before the Deportation Board for:

Unauthorized purchase and clandestine remittance of US$130,000 without Central Bank license.
Attempted bribery of Philippine and US officers to evade prosecution (charges on attempted bribery later dismissed in court).

The Deportation Board issued arrest warrants; petitioners posted ₱10,000 surety and ₱10,000 cash bonds each, securing provisional release.
Petitioners moved to dismiss for lack of deportation grounds and jurisdiction; the Board denied the motion on February 9, 1953.

Petitioners filed a petition for habeas corpus and/or prohibition in the Supreme Court, which assigned it to the Court of First Instance of Manila as Sp. Proc. No. 20037.
The lower court issued a preliminary injunction (upon ₱5,000 bonds each) restraining the Board from hearing the charges pending resolution.
The Board answered, defending its jurisdiction and power to investigate, arrest, and fix bonds under Section 69 of the Revised Administrative Code.

The presidential delegation of investigatory power to the Deportation Board.
The Board’s authority to issue arrest warrants and fix provisional-release bonds under Sec. 69, R.A.C.

The petition was dismissed; petitioners appealed to this Court (G.R. No. L-10280).

Whether the President may deport aliens absent explicit legislative grant.
Whether such power to deport presupposes legislative authorization of grounds for deportation.

Whether the President’s investigatory power may be delegated to the Deportation Board.
Whether the Board can validly issue warrants of arrest and fix bonds for administrative investigation.

Whether warrants of arrest for administrative purposes require a judge’s prior determination of probable cause under Article III, Sec. 1 of the Constitution.

Whether EO 398 (1951), empowering the Board to issue arrest warrants and fix bonds, is lawful.