To my mind, the questioned acts of the Boards were done absolutely within their quasi-judicial functions. Therefore, the rule laid down in Filipinas Engineering and Machine Shop vs. . Ferrer (135 SCRA 25) and Lupangco vs. Court of Appeals (160 SCRA 848) does not apply.
- G.R. Number: G.R. No. 95122-23
- Promulgated: 1990-09-04
Doctrine
Boards such as the Board of Commissioners and Board of Special Inquiry are quasi-judicial bodies and their actions within quasi-judicial functions are subject to the established appellate rule.
When claimed citizenship is the central issue, its determination by administrative immigration bodies is not merely incidental but a substantive adjudication subject to review.
A party asserting a valid foreign marriage must prove the foreign law, compliance therewith, and the fact of the marriage; absence of such proof undercuts claims dependent on foreign marital status.
Facts
The petitioners, the Board of Commissioners and Board of Special Inquiry, are treated as quasi-judicial bodies whose questioned acts were performed within their quasi-judicial functions.
In 1961 the BOC/BSI proceeded to determine claimants' asserted Philippine citizenship; the claimed citizenship was the central and indispensable issue before the BSI.
William Gatchalian's claim to Philippine citizenship relied largely on self-serving oral testimony, lacked official Philippine or foreign documentary proof, and invoked presumptions without essential factual proof.
No documentary proof was presented of a 1926 marriage in China to Chu Gim Tee, nor proof of the applicable Chinese law or compliance with it.
Issues
Whether this Court should treat the present matter as an exception and decide Gatchalian's citizenship instead of remanding to the Regional Trial Court.
Whether the Boards acted within their jurisdiction in resolving the claim of Philippine citizenship.
Whether Gatchalian adequately proved foreign marriage and other facts essential to his claim of Philippine citizenship.
Ruling
The petition for certiorari and prohibition in G.R. Nos. 95122-23 is GRANTED; the challenged orders of respondent judges are SET ASIDE and the Court REAFFIRMS that respondent William Gatchalian is not a Philippine citizen.
The Court rejects treating the present case as an exception that would permit the Supreme Court to decide citizenship instead of applying the rule conferring exclusive appellate jurisdiction to the Court of Appeals.
Keywords
deportation proceedings, quasi-judicial bodies, exclusive appellate jurisdiction, Batas Pambansa Blg. 129, certiorari, prohibition with injunction, Regional Trial Court, forum-shopping, grave abuse of discretion, Commission on Immigration and Deportation, Chua Hiong vs. Deportation Board (96 Phil. 665), conclusive of his citizenship, Co vs. Deportation Board (78 SCRA 104, 107), Civil Case No. 90-54214, Civil Case No. 3431-V-90, Filipinas Engineering and Machine Shop vs. Ferrer (135 SCRA 25), Lupangco vs. Court of Appeals (160 SCRA 848), board, boards, citizenship