Case Digest (G.R. No. 8168)
Facts:
The case of The United States vs. Li Sui Wun arose on December 24, 1914, in the Court of First Instance of Manila, concerning the deportation of Li Sui Wun, the defendant and appellant. Li Sui Wun arrived in the Philippines through the port of Manila on February 28, 1911, aboard the steamship Loongsang. Upon his arrival, he was granted entry without objection based on presenting a "section six certificate," which he utilized as evidence of his eligibility to enter the territory. However, it was later claimed that he was engaged as a laborer without being registered as a Chinese laborer—an act that violated local immigration laws leading to his deportation.
After a review of the case, Judge Simplicio del Rosario ruled in favor of the government, determining that Li Sui Wun should be deported. In response, Li Sui Wun appealed, raising multiple assignments of error, notably questioning whether his admission through the "section six certificate" barred his depor
Case Digest (G.R. No. 8168)
Facts:
- Commencement of the Action
- The case originated in the Court of First Instance of Manila on December 24, 1914.
- The purpose of the suit was to deport the defendant and appellant, Li Sui Wun, from the Philippine Islands pursuant to Act No. 702 of the United States Philippine Commission.
- Admission and Entry of the Defendant
- The defendant arrived at the port of Manila on February 28, 1911, aboard the steamship Loongsang.
- Upon arrival, he presented his “section six certificate” and was admitted without objection.
- The certificate, which indicated his occupation as a merchant (or as qualified for the privileges accorded to certain classes), was the basis for his lawful entry into the Philippine Islands.
- Allegation and Basis for Deportation
- It was alleged that the defendant, now engaged as a laborer, had failed to register as a Chinese laborer—a requirement under Philippine immigration regulations.
- The contention was raised that his original admission under the "section six certificate" was limited to a specific purpose (visiting the carnival or exposition) and did not extend to a permanent or general right to reside, particularly as a laborer.
- Judicial Proceedings in Lower Court
- The Court of First Instance, after hearing both parties, decided in favor of deporting the defendant.
- This decision prompted an appeal to the higher court (G.R. No. 10670, decided November 04, 1915).
Issues:
- Legal Standing of the “Section Six Certificate”
- Whether the certificate, by which the defendant was admitted without objection, confers upon him the full rights granted to other aliens from the most favored nations.
- Whether the certificate’s displayed purpose (e.g., as a merchant, tourist, or student) inherently limits the period during which the holder may lawfully remain in the country.
- Change of Vocation and Its Impact on Deportation
- Whether a change in circumstance—from originally entering as a merchant, student, or tourist, to subsequently becoming a laborer—is a sufficient ground for deportation.
- Whether the subsequent status as a laborer conflicts with the original basis of legal entry under the “section six certificate.”
- Application of Federal Jurisprudence
- How Federal court decisions regarding Chinese aliens and the permanence of the rights granted under the certificate, regardless of later status changes, apply to the facts of the case.
- Whether analogous cases involving minor children of resident merchants or students who turn laborers support the argument against deportation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)