G.R. Nos. 95122-23 and 95612-13; May 31, 1991
Board of Commissioners (Commission on Immigration and Deportation), et al. vs. Hon. Joselito Dela Rosa, et al. and Hon. Teresita Dizon Capulong, et al.; William T. Gatchalian vs. Board of Commissioners, et al.

FACTS

The consolidated petitions stem from deportation proceedings against William Gatchalian. In 1961, the Board of Special Inquiry admitted him as a Filipino citizen. In 1962, the Board of Commissioners, acting under a Justice Secretary memorandum, reviewed the case motu proprio and reversed the decision, ordering his exclusion. This 1962 decision was upheld by the Supreme Court in Arocha vs. Vivo (1967). However, in 1973, the Board of Special Inquiry recommended reversing the 1962 exclusion order, and the Acting Immigration Commissioner issued an order reaffirming Gatchalian’s 1961 admission and recalling his arrest warrant.
In 1990, the NBI recommended charging Gatchalian with immigration violations. The Secretary of Justice endorsed this to the Commissioner of Immigration. The Board of Special Inquiry subsequently issued a subpoena for a preliminary investigation. Gatchalian filed two civil cases in different RTCs to enjoin the deportation proceedings. The RTC judges issued restraining orders. The immigration officials then filed these petitions for certiorari, arguing the RTCs interfered with the Commission’s exclusive jurisdiction. Gatchalian filed a counter-petition seeking a declaration of his Filipino citizenship.

ISSUE

The primary issue is whether the Regional Trial Courts have jurisdiction to enjoin the deportation proceedings conducted by the Commission on Immigration and Deportation.

RULING

The Supreme Court ruled that the RTCs have no jurisdiction. The legal logic is anchored on the doctrine of primary jurisdiction and the statutory authority of the immigration commission. Under Commonwealth Act No. 613 , as amended, the Commission on Immigration and Deportation possesses exclusive administrative jurisdiction to conduct deportation proceedings. This includes the authority to determine factual questions regarding an alien’s entry and right to remain.
The Court emphasized that judicial intervention is premature and impermissible while these administrative proceedings are pending. The proper recourse for an aggrieved party is to exhaust administrative remedies by appealing an adverse deportation order to the Office of the President, and only thereafter may judicial review be sought through the appropriate special civil action. The RTC orders restraining the deportation process constituted a clear grave abuse of discretion for lack of jurisdiction. Consequently, the Court granted the petitions, set aside the RTC orders, and made the temporary restraining orders permanent, directing the dismissal of the civil cases before the RTCs. The deportation proceedings before the Commission were to proceed.