FACTS:

The case involves three petitions seeking to set aside the decisions of the Court of Appeals and the Regional Trial Court upholding the preparation and filing of deportation charges against Jimmy T. Go. The petitions arose from a complaint for deportation initiated by Luis T. Ramos, alleging that Jimmy is an illegal and undesirable alien. Luis presented Jimmy's birth certificate indicating his citizenship as "FChinese" and argued that the document appeared to be tampered. He also alleged that Jimmy procured a Philippine passport through the use of falsified documents and untruthful declarations. Jimmy denied the allegations, claiming that he is a natural-born Filipino as his father elected Philippine citizenship. The case was initially dismissed, but the Board of Commissioners reversed the dismissal and directed the preparation and filing of deportation charges against Jimmy. A charge sheet was filed against Jimmy, charging him with violating immigration laws.

Carlos and Jimmy filed a petition before the RTC of Pasig City, seeking to annul and set aside the March 8, 2001 Resolution of the Board of Commissioners, the Charge Sheet, and the proceedings had therein. They challenged the jurisdiction of the Board to continue with the deportation proceedings. In the meantime, the Board issued a decision ordering the apprehension and deportation of Jimmy. Carlos and Jimmy filed a supplemental petition, but it was dismissed by the trial court. Carlos and Jimmy questioned the dismissal of their petition before the Court of Appeals, but it was likewise dismissed. The Court of Appeals held that the Board has the exclusive authority and jurisdiction to try and hear cases against an alleged alien, and to determine their citizenship. The appellate court also found that Carlos failed to elect Philippine citizenship within a reasonable period. Carlos and Jimmy filed petitions for review on certiorari before the Supreme Court. Meanwhile, Jimmy was apprehended and detained pending deportation. Jimmy filed a petition for habeas corpus, but it was dismissed by the trial court. Jimmy moved for reconsideration, but was denied. Jimmy assailed the trial court's orders before the Court of Appeals.

Jimmy filed a petition for certiorari and prohibition before the appellate court, assailing the orders of the trial court. The Court of Appeals granted the petition and enjoined the deportation of Jimmy until the issue of his citizenship is settled by the court. The Court of Appeals ruled that the issuance of a warrant to arrest and deport Jimmy, without proof of his violation of bail conditions, is arbitrary and unjust. The court emphasized the importance of due process in deportation proceedings, particularly when it may unjustly expel someone who may be a Filipino citizen. The Bureau of Immigration and Deportation, along with their agents, are enjoined from deporting Jimmy until the court has settled the issue of his citizenship. The court denied the motion for reconsideration. The Commissioner of the Bureau of Immigration, along with his intelligence officers, filed a petition before the Supreme Court, questioning the court's decision. The parties raised arguments regarding the failure to implead an indispensable party, prescription of the Bureau's cause of action, sufficiency of evidence to prove citizenship, due process in the deportation proceedings, and dismissal of the petition for habeas corpus. Carlos and Jimmy argued that the deportation proceedings should be nullified due to the non-inclusion of Carlos as an indispensable party. Jimmy also claimed that the cause of action for his deportation has prescribed.

Jimmy and Carlos are aliens residing in the Philippines who were facing deportation proceedings initiated by the Board of Commissioners (Board) of the Bureau of Immigration. The Board asserted that Carlos is a Chinese citizen and, therefore, Jimmy should be deported as well. Jimmy filed a petition for certiorari and prohibition with the Regional Trial Court (RTC) to challenge the deportation order.

Jimmy argued that the deportation case against him was dependent on the citizenship of his father, Carlos, even though Carlos was not made a party in the proceedings. He claimed that Carlos was unjustly stripped of his citizenship without being given the opportunity to present evidence to prove his Philippine citizenship. Jimmy also contended that the Board had no grounds to question his citizenship since he and his father were born, raised, and lived in the Philippines all their lives, spoke fluent Filipino languages, engaged in businesses reserved for Filipinos, exercised their right to suffrage, enjoyed rights and privileges exclusive to citizens, and possessed Philippine passports issued to them.

Carlos supported Jimmy's claim to Philippine citizenship and presented arguments to sustain his own claim as well. He believed that his citizenship was essential to establish the citizenship of his son.

Both Jimmy and Carlos sought judicial intervention, asserting that the claim to citizenship is substantial enough to warrant a full-blown, adversarial trial-type proceeding where the rules of evidence are strictly observed. They argued that the RTC has jurisdiction to conduct such proceedings to protect their rights.

ISSUES:

1. Whether the deportation proceeding should be nullified for failure to implead Carlos as an indispensable party.

2. Whether judicial intervention is necessary in determining the claim to Philippine citizenship of Carlos and Jimmy.

3. Whether the 5-year period for deportation should be counted from the time the complaint for deportation was filed.

4. Whether Carlos is an indispensable party in the case.

5. Whether the doctrine of jus soli applies to confer Philippine citizenship.

6. Whether the Philippine Bill of 1902 and the Jones Law of 1916 confer Philippine citizenship.

7. Whether Carlos, as an illegitimate child of a Filipina, automatically acquires Philippine citizenship.

8. Whether the election of one's citizenship confers Philippine citizenship.

9. Whether the election of Philippine citizenship has a prescribed time period.

10. Whether Carlos' exercise of suffrage indicates his belief in being Filipino.

11. Whether Carlos and Jimmy have proven their Philippine citizenship.

12. Whether due process was observed in the deportation proceedings.

13. Whether there was a violation of due process in the administrative proceedings against Jimmy Go.

14. Whether the petition for certiorari was the appropriate remedy to question Jimmy Go's apprehension and detention.

15. Whether the bail granted to Jimmy Go was valid.

16. Whether the petition for habeas corpus was proper considering the availability of other remedies.

17. Whether the proceedings before the Board were void for failure to implead Jimmy Go's father.

18. Whether or not a writ of habeas corpus can be issued to question the legality of detention after the person has been duly charged in court.

19. Whether or not the cancellation of bail can be assailed through a petition for habeas corpus.

20. Whether or not the Regional Trial Courts have the authority to release an alien on bail in habeas corpus proceedings for deportation.

RULING:

1. The deportation proceeding should not be nullified for failure to implead Carlos as an indispensable party. The court held that once the citizenship of an individual is put into question, it necessarily has to be decided upon. The government should not be precluded from questioning one's claim to Philippine citizenship, especially when the same has never been decided by any tribunal.

2. Judicial intervention is not necessary in determining the claim to Philippine citizenship of Carlos and Jimmy. The court stated that cases involving issues on citizenship are sui generis, and decisions declaring the acquisition or denial of citizenship cannot govern a person's future status with finality. The government has the right to question one's claim to Philippine citizenship, even if it has never been adjudicated before.

3. The 5-year period for deportation should be counted from the time the complaint for deportation was filed. The legal possibility of bringing the action determines the starting point for the computation of the period of prescription.

4. Carlos is not an indispensable party in the case as he does not stand to be benefited or injured by the judgment of the suit. The principal issue that will be decided on is the propriety of the deportation.

5. No, the doctrine of jus soli does not apply to confer Philippine citizenship.

6. No, the Philippine Bill of 1902 and the Jones Law of 1916 do not confer Philippine citizenship.

7. No, Carlos, as an illegitimate child of a Filipina, does not automatically acquire Philippine citizenship without evidence.

8. No, the election of one's citizenship does not confer Philippine citizenship.

9. Yes, the election of Philippine citizenship must be made within three years from reaching the age of majority.

10. No, Carlos' exercise of suffrage does not indicate his belief in being Filipino.

11. No, Carlos and Jimmy have not proven their Philippine citizenship.

12. Yes, due process was observed in the deportation proceedings.

13. The court held that there was no violation of due process in the administrative proceedings against Jimmy Go. Despite not being furnished with a copy of the subject Resolution and Charge Sheet, Jimmy Go was given ample opportunity to explain his side and present evidence, satisfying the demands of administrative due process.

14. The court agreed with Jimmy Go that the petition for certiorari and prohibition was the appropriate remedy to question his apprehension and detention, considering the alleged grave abuse of discretion by the petitioners. The court found that it was not necessary to strictly adhere to the availability of an ordinary appeal when what was at stake was the liberty of the individual.

15. The court did not directly address the validity of the bail granted to Jimmy Go.

16. The court disagreed with the petitioners and held that the petition for habeas corpus was proper. The purpose of a habeas corpus petition is to determine the legality of a person's detention, and if found illegal, to order their release. The court rejected the argument that the petition became moot and academic because Jimmy Go was no longer detained.

17. The court did not directly address the issue of impleading Jimmy Go's father in the proceedings before the Board.

18. Once a person detained is duly charged in court, he may no longer question his detention through a petition for the issuance of a writ of habeas corpus. His remedy would be to quash the information and/or the warrant of arrest duly issued.

19. The cancellation of bail cannot be challenged via a petition for a writ of habeas corpus.

20. When an alien is detained by the Bureau of Immigration for deportation pursuant to an order of deportation by the Deportation Board, the Regional Trial Courts do not have the power to release such an alien on bail even in habeas corpus proceedings because there is no law authorizing it.

PRINCIPLES:

• Once the citizenship of an individual is put into question, it must be decided upon.

• Decisions declaring the acquisition or denial of citizenship do not govern a person's future status with finality.

• The government has the right to question one's claim to Philippine citizenship, even if it has never been adjudicated before.

• The period for deportation should be counted from the time the complaint for deportation was filed.

• An indispensable party is a party in interest without whom no final determination can be had of an action, and who shall be joined either as plaintiff or defendant.

• Res judicata does not apply as a matter of course in citizenship proceedings.

• The Board has the authority to hear and determine deportation cases, but judicial determination is allowed when there is substantial evidence supporting the claim of citizenship.

• The decision of the Board on the question of citizenship is subject to review by the courts.

• The doctrine of jus soli, or citizenship by place of birth, was never extended to the Philippines. Only those individually declared citizens by court decision based on jus soli benefit from it.

• Legitimate children follow the citizenship of the father, while illegitimate children follow the nationality of the mother.

• An illegitimate child of a Filipina automatically becomes a citizen of the Philippines without needing to perform any act.

• The election of Philippine citizenship should be made within three years from reaching the age of majority.

• The exercise of rights and privileges exclusive to Filipinos is not conclusive proof of citizenship.

• The burden of proving Philippine citizenship rests upon the claimant.

• Deportation proceedings are administrative and need not strictly adhere to the rules of ordinary court proceedings.

• Due process requires that parties are given the opportunity to be heard before a judgment is rendered.

• The availability of an ordinary appeal does not preclude the filing of a petition for certiorari when there is alleged grave abuse of discretion.

• The purpose of a petition for habeas corpus is to determine the legality of a person's detention and order their release if found illegal.

• The writ of habeas corpus can only be issued to inquire into the legality of a person's detention as of, at the earliest, the filing of the application for the writ of habeas corpus.

• The remedy to question detention after being duly charged in court is to quash the information and/or warrant of arrest.

• The term "court" in the context of habeas corpus proceedings includes quasi-judicial bodies of governmental agencies authorized to order confinement.

• The cancellation of bail cannot be assailed through a petition for habeas corpus.

• Regional Trial Courts do not have the authority to release an alien on bail in habeas corpus proceedings for deportation, as there is no law authorizing it.