United States v. Ang
REITERATIONFacts
The Antecedents: The action was instituted to deport the defendant-appellant, Angel Ang, from the Philippine Islands. The basis for the action was that he was found in the islands without the certificate required by Act No. 702, on the theory that he was a Chinese subject and a laborer. Procedural History: The lower court found that the defendant was a full-blooded Chinaman, a laborer, and was without the required certificate under Act No. 702, and ordered his deportation. The Petition: The defendant appealed the judgment of deportation to the Supreme Court.
Issue(s)
Whether the defendant-appellant, born in the Philippine Islands of a Chinese father and a Filipino mother, is subject to deportation as an unregistered Chinese laborer under Act No. 702. Whether a child born in the Philippine Islands to a Chinese father and a Filipino mother is presumed to be a citizen of the country.
Ruling
The judgment of deportation is revoked, and the complaint is ordered dismissed, with the defendant discharged from custody.
Ratio Decidendi
On the issue of whether the defendant-appellant is subject to deportation as an unregistered Chinese laborer under Act No. 702: The Court found that while the lower court determined the defendant to be a full-blooded Chinaman and a laborer without the required certificate, these findings were insufficient to warrant deportation. The evidence established that the defendant was born within the Philippine Islands to a Chinese father and a Filipino mother. Although he had spent a short time in China during his minority, he had lived in the Philippine Islands practically all his life. The Court held that birth within the Philippine Islands, coupled with a Filipino mother, conferred a presumption of citizenship that exempted him from the provisions of Act No. 702, which applied to Chinese laborers entering or residing in the islands without the requisite documentation. The appearance of being a full-blooded Chinaman, as found by the lower court, was not determinative in light of his birth and parentage within the jurisdiction. On the issue of whether a child born in the Philippine Islands to a Chinese father and a Filipino mother is presumed to be a citizen of the country: The Court affirmed the principle that a child born in the Philippine Islands, whose parents are a Chinaman and a Filipino woman, is prima facie presumed to be a citizen of the country. This presumption of citizenship, arising from birth within the territory and having a Filipino mother, meant that such a child was not subject to the registration requirements mandated by Act No. 702 for alien laborers. The Court cited several previous decisions, including U.S. vs. Ong Tianse, U.S. vs. Lim Bin, U.S. vs. Tan Chuy Ho, and U.S. vs. Wong Kim Ark, to support this established legal principle regarding citizenship by birth in the Philippines.
Main Doctrine
A child born within the Philippine Islands to a Chinese father and a Filipino mother is presumed to be a citizen of the Philippines and is not required to register under Act No. 702, thus exempt from deportation proceedings based on being an unregistered Chinese laborer.