Vy Lion Lin v. Insular Collector of Customs
REITERATIONFacts
The Antecedents: Two adult Chinese aliens, Soon Shing and Who Chan Ton, arrived at the port of Manila from Japan seeking admission into the Philippine Islands. They did not possess the required 'section six certificate' for the admission of Chinese aliens into territory of the United States. Procedural History: Their right to enter was denied by the board of special inquiry, which was affirmed by the Collector of Customs. A petition for a writ of habeas corpus was filed in the Court of First Instance of Manila, which ordered the admission of the two Chinamen without the certificate. The Attorney-General appealed this decision to the Supreme Court. The Appeal: The Attorney-General appealed the decision of the lower court, arguing that the court erred in finding that the 'section six certificate' was not necessary for the admission of Chinese persons, particularly those who claimed to be of a 'privileged class' and unable to obtain the certificate due to fear of their own government. The core issue before the Supreme Court was whether the absence of the 'section six certificate' barred the admission of these Chinese aliens.
Issue(s)
Whether adult Chinese aliens who have never been in the territory of the United States may enter the Philippine Islands without the "section six certificate." Whether the lower court erred in finding that the "section six certificate" is not necessary for the admission of Chinese persons of the privileged class.
Ruling
The Supreme Court revoked the judgment of the lower court and ordered that the two Chinamen be returned to the Collector of Customs to carry into effect the order of deportation. The Court held that the 'section six certificate' is mandatory for the admission of Chinese aliens into the Philippine Islands, with very limited exceptions.
Ratio Decidendi
On Whether adult Chinese aliens who have never been in the territory of the United States may enter the Philippine Islands without the "section six certificate." The Court held that the 'section six certificate' is an absolute requirement for the admission of Chinese aliens into the Philippine Islands, which is considered territory of the United States for immigration purposes. The decision emphasized that this rule is well-settled and supported by numerous decisions from both the department of customs and the courts. The only exceptions recognized by law are for the wife or minor children of a Chinese alien who is already a resident of the territory. The circumstances of the two Chinamen, including their escape from China to Japan and their fear of returning, did not exempt them from this requirement. The Court found that the lower court erred in believing that these circumstances placed them in a 'privileged class' exempt from the statutory mandate. The Court's opinion is that no Chinese alien, regardless of their occupation or status, has a right to enter the territory of the United States without the prescribed certificate. On Whether the lower court erred in finding that the "section six certificate" is not necessary for the admission of Chinese persons of the privileged class. The Supreme Court found that the lower court committed an error in its determination that the 'section six certificate' was not necessary for the admission of the two Chinese aliens, even if they were considered to be of a 'privileged class.' The Court reiterated that the requirement of the 'section six certificate' is absolute for all Chinese aliens seeking entry, with the exception of wives and minor children of residents. The Court stated that the notion of a 'privileged class' that could bypass this statutory requirement was not supported by law or jurisprudence. The inability of the aliens to obtain the certificate due to their fear of returning to China was deemed irrelevant to the legal requirement for admission. Therefore, the lower court's reliance on the supposed 'privileged class' status and the impossibility of obtaining the certificate was a misapplication of the law.
Main Doctrine
The Court held that adult Chinese aliens, regardless of their circumstances or reasons for leaving their home country, must possess the 'section six certificate' to be admitted into the Philippine Islands, which is considered territory of the United States for immigration purposes. The exceptions to this rule are strictly limited to the wife or minor children of a Chinese alien already residing in the territory.