G.R. No. 6463 - Alcala vs. Pabalan

The case involved the deportation of Benito Lao Chueco from the Philippine Islands under Act No. 702, based on the allegation that he was a Chinese laborer who had failed to register as required by law.
The action was initiated by the United States as the plaintiff and appellee.

The first complaint was presented in the court of the justice of the peace in the municipality of Surigao on February 28, 1917, and was signed by an officer of the Philippine Constabulary.
The record indicates that the defendant appeared in the court on February 27, 1917—prior to the presentation of the complaint—and posted a P600 bond for his liberty.
On March 16, 1917, the defendant appeared and formally renounced his right to a preliminary examination.
On the same day, the justice of the peace found reasonable grounds to believe the defendant was guilty of the offense charged and ordered him to be held for trial in the Court of First Instance.
Notice was subsequently issued to the bondsmen to ensure his presence in the Court of First Instance on April 14, 1917.
On April 25, 1917, a warrant of arrest was requested by the prosecuting attorney of the Province of Surigao, though the record does not explain the reason for this action.
A new complaint was then presented on April 27, 1917, in the Court of First Instance, whereupon the defendant was arraigned, pleaded not guilty, and the trial was immediately set down.

The defendant, through his attorney, motioned to postpone the trial on grounds of sickness and the absence of his witnesses.

The motion cited his physical inability to present his witnesses and prepare adequately for his defense due to his ill health.
The court denied this motion for a continuance, ordering the trial to proceed.

Despite the initial denial, during the trial only two prosecution witnesses were presented.
At the close of the prosecution’s evidence, the defendant again requested a continuance, reiterating his sickness and inability to present his defense witnesses.
The motion was once more denied, and the defendant then informed the court that he was physically unable to testify on his own behalf.
As a result, the court promptly ordered the deportation of the defendant from the Philippine Islands.
Immediately following the deportation order, the defendant sought to appeal the decision to the Supreme Court and requested his release on bond pending the appeal, which the trial court also denied.

Compelling the accused to try his case despite his illness, which rendered him incapable of adequately defending himself.
Denial of a postponement of the trial, which prevented him from gathering necessary witnesses and evidence for his defense.
Ordering his deportation without affording him the opportunity to properly defend himself.

In response, the Honorable Quintin Paredes acknowledged that the defendant did not receive a fair trial and recommended remanding the record for a new trial.
The Attorney-General pointed out that the evidence presented was objectionable due to its hearsay nature and speculative character.
The record further detailed procedural irregularities:

The initial complaint was not presented by an authorized officer, referencing previous cases (U. S. vs. Lee Chiao, U. S. vs. De los Santos, U. S. vs. Li Choy).
The defendant was forced to trial on the same day as the complaint without being in a condition to testify, thus denying him the chance to produce witnesses.

The lower court also denied the defendant’s motion for liberty under bond during his appeal, despite his entitlement under similar deportation proceedings.
The jurisprudence distinguishes this case from those involving Chinese immigrants seeking admission to the United States, where bail may be denied under the Chinese Exclusion Law.

Whether the defendant was given a fair and full hearing in the lower courts.

Did the defendant receive an opportunity to present his evidence and witnesses adequately before being forced to trial?
Was his illness appropriately considered in allowing a postponement for a proper defense?
Did the rapid progression of the case and the procedural irregularities violate the defendant’s right to due process?

Whether the deportation order was rendered valid in the context of these procedural irregularities.

The issue of whether the order to deport was lawful without affording adequate evidentiary submissions and the right to defend himself.

Whether the denial of bail during the pendency of the appeal was justified under the applicable laws for deportation proceedings.