Tan Beko v. Insular Collector of Customs
REITERATIONFacts
The Antecedents: Tan Beko arrived in Manila from China on or about July 17, 1910, seeking admission as the minor son of a resident Chinese merchant. He claimed to be less than 21 years of age. Procedural History: Tan Beko was brought before a board of special inquiry. The board heard witnesses who testified that he was a minor. However, the board refused to hear a material witness presented by Tan Beko and denied him entry, alleging he was over 21 years of age. An appeal to the Insular Collector of Customs affirmed the board's decision. The Petition: Tan Beko filed a petition for habeas corpus, alleging illegal detention. He contended that the board of special inquiry rendered a decision adverse to him without sufficient evidence and arbitrarily refused to hear a material witness. He further argued that the Insular Collector of Customs erred in affirming the decision.
Issue(s)
Whether the board of special inquiry erred in denying entry to the petitioner without sufficient evidence. Whether the board of special inquiry committed an error in refusing to hear a material witness presented by the petitioner.
Ruling
The Supreme Court affirmed the decision of the Insular Collector of Customs, denying the petition for habeas corpus. The Court found that the board of special inquiry had sufficient evidence to support its decision and that the refusal to hear the witness was justified.
Ratio Decidendi
On Issue 1: The Court held that the physical appearance of the petitioner was sufficient evidence for the board of special inquiry to determine his age. The board was not obliged to believe the testimony of witnesses stating the petitioner was a minor when his appearance suggested otherwise. The Court emphasized that the person of an alien seeking admission is evidence in such investigations, and the board may consider it to determine the applicant's age and the credibility of witnesses. Therefore, the decision was not rendered without evidence to sustain it. On Issue 2: The Court found that the refusal to hear the witness, Tay Chico, was justified. Tay Chico was called on July 29, 1910, and stated he had left his certificate of residence and cedula at home. The board refused to permit him to testify without presenting his cedula as required by Act No. 1189. Subsequent rehearings were granted on August 5 and August 22, 1910, providing ample time for the witness to obtain his documents. His failure to do so was attributed to him or the petitioner, and the witness was not presented again. Thus, the refusal to hear him under those circumstances was not an error.
Main Doctrine
The physical appearance of an alien applicant for admission is admissible evidence before a board of special inquiry, and may be used by the board to determine the applicant's age and the credibility of witnesses. The Supreme Court will not disturb factual findings of administrative bodies, such as boards of special inquiry, if supported by evidence, including the applicant's physical presentation.