fact that if any Filipino wished to return to the US during the tenure of this program then they would be facing an uphill battle against a quota of only 50 Filipinos allowed into the US per year. This act was deemed unconstitutional by the United States Supreme Court in 1940 after 2,190 Filipinos had returned to the Philippines. It was succeeded by the Nationality Act of 1940. See also History of the Philippines (1898–1946) References Filipino-American history Legal history of the Philippines