The Bureau of Immigration (BI) has ordered the release of Australian nun Patricia Fox after a day in detention.
Fox, a missionary of the Sisters of Our Lady of Sion, joined an global fact-finding mission in the southern Philippines this month to look into reported violations of the rights of farmers and indigenous people, Pahilga added.
In a two-page recommendation to Morente, Santos noted that while Fox was alleged to have previously taken part in protest actions by farmers, she was not doing so at the time the authorities served her the mission order on Monday, April 16.
Fox has been working with farmers and indigenous peoples in the country for almost three decades. Her arrest was based on a mission order issued by Commissioner Jaime Morente.
Santos said that inquest proceedings applies only to those aliens caught in the act violating such.
The missionary nun recently joined an global fact-finding and solidarity mission that look into human rights abuses against farmers and Lumads in Mindanao.
It said Fox was issued a missionary visa on October 15 last year, which is valid until September 9 this year.
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A 71-year-old Australian nun was held by police in the Philippines for 22 hours, accused of involvement in political activities, in what is seen as part of a clampdown on foreigners instigated by President Rodrigo Duterte.
Friends of an Australian nun detained in the Philippines say they're shocked Rodrigo Duterte's government has arrested her, saying the "gentle soul" has been "hit with a sledgehammer".
Sr Fox's detention came a day after Giacomo Filibeck, a Socialist Party official from the European Union who had criticised Mr Duterte's brutal anti-drugs crackdown, was deported.
The BI's move, which was supported by Malacañang and the Department of Justice, drew flak from the opposition, among them, the Makabayan bloc at the House of Representatives.
Her lawyer said she visited Tagum City to document reported human rights violations against farmers in Mindanao for a report intended for government agencies. "Helping the poor is not a crime and joining peace activities to advocate for peasant welfare and human rights is not against the law", they added.
"The immigration department is barking (up) the wrong tree on this one. Sis".