G.R. No. L-21076 - Wong Woo Yiu vs. Vivo

Petitioner Wong Woo Yiu, also known as No Yao, claimed that she married Perfecto Bias— a Filipino citizen— on January 15, 1929, in Chingkang, China before a village leader, Chua Tio.
She asserted that the couple had several children who are all residing in the Philippines, thus establishing a husband–wife relationship.
In her initial immigration proceedings, she declared that 1961 was her first entry into the Philippines to join her husband.

On June 28, 1961, the Board of Special Inquiry No. 3 rendered a decision admitting petitioner into the country as a non-quota immigrant, finding her marriage valid.
This decision was subsequently affirmed on July 12, 1961 by the Board of Commissioners, and the petitioner was duly informed via a letter sent by the Secretary of the Board.

On June 28, 1962, a newly constituted Board of Commissioners rendered a motu proprio decision reversing the initial favorable decision, finding that there was no substantial proof of a husband–wife relationship due to inconsistencies in the evidence related to the marriage.
The Board highlighted discrepancies in the petitioner's and Perfecto Bias’ statements, noting conflicting dates regarding Perfecto Bias’ visits to China and the timing of his marriage.
A motion for a new trial was filed by the petitioner on August 9, 1962, seeking clarification on the points taken in the reversal, but it was denied for lacking merit.
Subsequently, on September 14, 1962, the petitioner initiated a petition for mandamus (filed before the Court of First Instance of Manila) with a preliminary injunction, which was treated by the court as a petition for certiorari.

After submission of a written stipulation of facts and documentary evidence by both parties, the court a quo rendered a decision granting the petitioner the relief prayed for in toto.
The decision of the lower court validated the original Board of Special Inquiry No. 3 decision and restrained the respondents from excluding the petitioner from the country.
Respondents (including Hon. Martiniano P. Vivo and others) later filed an appeal against the ruling of the lower court.

Whether the evidence (both documentary and oral) sufficiently established the petitioner’s claim that she is the lawful wife of Perfecto Bias.
Whether the numerous discrepancies and conflicting statements regarding the dates of marriage and Perfecto Bias’ travels to China undermine her marital claim.

Whether the marriage, allegedly celebrated before a village leader in China, fulfills the formal requisites under Philippine law for a valid marriage.
Whether the general rule (that foreign law, if not conclusively proved, is presumed to be the same as domestic law) applies in this context.

Whether the decision rendered by the newly constituted Board of Commissioners in 1962, which reversed the petitioner’s initial immigration approval, was justified based on the inconsistencies presented in the record.
Whether the procedural steps taken by the petitioner (motion for new trial and subsequent petition for mandamus) effectively sought redress against the reversal of the favorable decision.