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**Facts:**
1. **Arrival and Admission:**
– Teban Caoile and his three brothers arrived in Manila on June 7, 1961, applying for admission as Philippine citizens based on documentation issued by the Philippine Consulate General in Hong Kong.
– After a hearing, the Board of Special Inquiry allowed their admission on June 23, 1961, based on the assumption that Teban was the son of Antonio Caoile of Urdaneta, Pangasinan.
– The Board relied on various pieces of evidence: blood tests, income tax returns, and a statutory declaration from a schoolmate in Hong Kong.
2. **Actions of the Board of Commissioners:**
– The Board of Commissioners had a divided reaction to the Board of Special Inquiry’s decision: Commissioner Emilio L. Galang voted for exclusion while Deputy Commissioners Francisco de la Rosa and Felix Talabis simply noted it and signed below.
3. **Identification and Normal Life:**
– On July 10, 1961, Teban received Identification Certificate No. 15648 indicating his admission as a Philippine citizen.
– Teban then participated in various civic activities such as voting, obtaining a passport, paying taxes, and working.
4. **Review by Secretary of Justice:**
– On January 24, 1962, the Secretary of Justice issued Memorandum Order No. 9, declaring that past decisions of the Board of Commissioners were set aside, and instructed a review of all such decisions with an emphasis on those involving citizenship claims.
– The review was to be conducted with the burden of proof on the claimant and favoring the government in cases of doubt.
5. **Reversal and Exclusion:**
– On June 23, 1962, under the authority of Memorandum Order No. 9, a new Board of Commissioners (Vivo, Rañola, and Gaston) reversed the Board of Special Inquiry’s decision and ordered Teban’s exclusion, citing inadequate documentation.
6. **Arrest and Habeas Corpus Petition:**
– Teban was arrested on March 10, 1964, following the exclusion order.
– Juan Garcia filed a writ of habeas corpus on March 12, 1964, which the Court of First Instance eventually denied after considering the case’s facts and testimonies.
7. **Appeal to Court of Appeals:**
– Garcia appealed the decision. The Court of Appeals allowed Teban’s provisional release on bail and eventually ruled in favor of him, granting habeas corpus and nullifying the exclusion warrant.
8. **Petition to the Supreme Court:**
– The Commissioner of Immigration and Capt. Macalinao brought the case to the Supreme Court, contesting the Court of Appeals’ decision.
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**Issues:**
1. Whether the Court of Appeals erroneously based its decision on unstipulated or unproven facts.
2. The validity of the two Deputy Commissioners’ actions in noting the Board of Special Inquiry’s decision.
3. Whether Juan Garcia was denied an opportunity to cross-examine Antonio Caoile.
4. The appropriateness of the Court of Appeals making findings on extraneous issues and alleged unsupported speculations.
5. Whether the Court of Appeals had jurisdiction over the facts given only legal issues were purportedly involved.
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**Court’s Decision:**
1. **Undisputed Facts:**
– The SC ruled that changes in facts should be determined if the conclusions by the CA were correct. The directive by the Secretary of Justice and the strict adherence to the Immigration Law were crucial in shaping the decision that invalidated Teban’s citizenship claim.
2. **Action by Deputy Commissioners:**
– The Court concluded the individual actions of Deputy Commissioners were rendered meaningless with Memorandum Order No.9 declaring proper protocol was not followed in the prior Board’s decision.
3. **Testimony of Antonio Caoile:**
– The SC determined that the testimony of Antonio Caoile, where he disowned Teban, conclusively affected the case’s outcome since it undermined Teban’s citizenship claim. The High Court noted that any suspicion over identity should have been contested during trial.
4. **Judgment on Extraneous Issues:**
– The SC found the CA had relied on unsupported findings like Antonio Caoile’s dubious identity and the allegedly forged report by the investigator, which brought inaccuracies blocking factual consistency.
5. **Jurisdiction of Court of Appeals:**
– The SC overruled the jurisdictional query since the appellate tribunal was mandated to rule on factual and legal facets involved.
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**Doctrine:**
The pivotal doctrine established is the validity of a ruling by the proper constituted Board should prevail. Additionally, citizenship claims must be thoroughly scrutinized, where the burden of proving claims lies heavily on the claimant, affirming any contradiction or doubt must favor the state.
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**Class Notes:**
– **Key Elements of Citizenship Claims:**
1. **Burden of Proof:** Claimant must establish citizenship beyond doubt (Sec. 27(b), Com. Act No. 613).
2. **Review Process:** Higher authority can motu proprio review decisions (Sec. 27(b), Com. Act No. 613).
3. **Public Interest:** Actions of public officials are subject to review and guidelines to act in public interest (Sec. 79[C], Rev. Admin Code).
– **Relevant Statutes:**
– Commonwealth Act No. 613 (Immigration Law)
– Article IV, sec 1(3) of the Philippine Constitution relating to citizenship by descent.
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**Historical Background:**
This case is entrenched in the landscape of post-war immigration scrutiny within the Philippines. As migration patterns increased, the necessity of confirming citizenship claims became paramount, especially with complications arising from Chinese-Filipino ancestry and residual war-time movements. The case epitomizes the stringent measures push for legal certainty in identity and citizenship, reflecting immigration law application against a backdrop of national security and public policy integrity.
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