Case Summary (G.R. No. 10670)
Background Facts
Li Sui Wun entered the Philippine Islands on February 28, 1911, aboard the steamship Loongsang, using a "section six certificate" that permitted his entry without objection. The plaintiff later alleged that he was working as a laborer without formal registration as a Chinese laborer, which constituted grounds for his deportation.
Judicial Proceedings and Ruling in Lower Court
Upon reviewing the case, Judge Simplicio del Rosario of the Court of First Instance sided with the plaintiff and ruled for the deportation of Li Sui Wun. The appellant subsequently appealed this decision.
Legal Question Presented
The primary legal question raised by Li Sui Wun was whether he could be deported from U.S. territory, having entered under a "section six certificate." The decision had to consider the implications of such a certificate regarding an individual's rights to remain in the territory.
Federal Court Precedents
In previous federal court decisions, it has been indicated that a Chinese person entering the United States with a "section six certificate" could remain indefinitely, even if they later changed their occupation to that of a laborer. The doctrine emphasizes that the “section six certificate” was not meant to impose limitations on the right to stay after lawful entry.
Rights Afforded by the “Section Six Certificate”
The legal interpretation of the "section six certificate" is critical. It is not merely an instrument for entering the territory but a facilitator that places the holder on equal footing with other aliens from nations given the most favored status regarding entry and residency. The certificate does not impose restrictions on the length of stay.
Impact of Admission Circumstances
The certificate stating the purpose of entry, whether as a student, merchant, or tourist, serves to convey that the individual has fulfilled the qualifications required for lawful entry but does not restrict the duration of their right to remain post-entry. This principle was affirmed by numerous federal court decisions that highlighted the importance of lawful admission.
Decision by the Higher Court
Reaching a conclusion, the higher court agreed with the Attorney General's appeal to reverse the lower court's decision. They concluded that since Li Sui Wun entered the Philippines lawfully with a "section six certificate," he held the right to remain in the territory without the concern of deportation merel
...continue readingCase Syllabus (G.R. No. 10670)
Case Background
- The case originated in the Court of First Instance of Manila on December 24, 1914.
- The action aimed to deport Li Sui Wun from the Philippine Islands under the provisions of Act No. 702 of the United States Philippine Commission.
- Li Sui Wun arrived in Manila on February 28, 1911, aboard the steamship Loongsang, presenting a "section six certificate" and was admitted without objection.
Legal Issues Presented
- The central legal issue is whether Li Sui Wun can be deported despite having entered the Philippines with a "section six certificate."
- The appellant claims that the certificate provides him with the right to remain in the territory of the United States indefinitely.
Court's Findings
- The Court noted that Li Sui Wun was admitted in December 1911 without objection, and the validity of his "section six certificate" was acknowledged.
- The Court cited previous cases indicating that a Chinese person admitted under a "section six certificate" may remain in the territory, even if they later change their status.
Precedents and Legal Doctrines
- The Court referenced the case of Gan Bun Cho vs. Collector of Customs which emphasized that the duration of stay for Chinese individuals admitted under such certi