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[18] 16 Phil. 534, 571-572 [1910], per Johnson, J.
[19] Under Law Instruction No. 31 issued on June 8, 1988, by Hon. Miriam Defensor
Santiago, then Commissioner of Immigration, "if the foreign embassy cancels the
passport of the alien, he loses the privilege to enter or remain in the country. The
automatic loss of the privilege obviates deportation proceedings under the Immigration
Act, Section 37; or the Administrative Code, Section 69." In such case, "the Board of
Commissioners may issue a summary judgment of deportation, which is immediately
executory." See also Office Memorandum Order No. 34 dated August 21, 1989, issued
by Acting Immigration Commissioner Bienvenido P. Alano Jr.
[20] Petitioner's Memorandum, p. 7; rollo, p. 120.
[21] Section 3 (m), Rule 131, Rules of Court.
[22] Section 37 (d), Philippine Immigration Act of 1940, as amended.
[23] Petitioner's Memorandum, p. 9; rollo, p. 122.
[24] See Velasco v. CA, 245 SCRA 677, July 7, 1995; Paredes v. Sandiganbayan, 193
SCRA 464, January 28, 1991; Cruz v. Montoya, 62 SCRA 543, February 25, 1975;
Matsura v. Director of Prisons, 77 Phil. 1050 [1947].
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