G.R. No. L-24068 April 23, 1974
PEDRO PACIS, as Acting Collector of Customs, and AGUSTIN MARKING, as Technical Assistant, Office of the Secretary of National Defense (OSND) and Administrator, General Affairs Administration, (GAA) Department of National Defense (DND), petitioners, vs. HON. FRANCISCO GERONIMO, as Presiding Judge, Branch XII, Court of First Instance of Manila and RICARDO SANTOS, respondents.

FACTS

The case originated from seizure proceedings initiated by petitioner Pedro Pacis, the Acting Collector of Customs, against a 1957 Mercury automobile owned by private respondent Ricardo Santos. The vehicle, originally imported tax-exempt, was acquired by Santos, who paid only P311.00 in duties. Upon receiving a report that the car was a “hot car,” Pacis investigated and found a significant discrepancy, determining the proper duty to be approximately P2,500.00. Based on this discrepancy, Pacis instituted seizure proceedings and issued a warrant of seizure and detention on July 22, 1964, leading to the car’s confiscation by DND agents.
In response, Santos filed a petition for certiorari and prohibition with the Court of First Instance of Manila, presided by respondent Judge Francisco Geronimo. Santos sought to restrain Pacis from proceeding with the seizure case and applied for writs of preliminary injunction and preliminary mandatory injunction to recover the vehicle. Despite Pacis’s opposition, Judge Geronimo granted these writs in an order dated December 21, 1964. Pacis’s motion for reconsideration was denied, prompting him to file the instant certiorari proceeding before the Supreme Court, challenging the lower court’s jurisdiction.

ISSUE

Whether or not the Court of First Instance had jurisdiction to entertain the petition for certiorari and prohibition and to issue injunctive writs against the Collector of Customs in a seizure and forfeiture case.

RULING

The Supreme Court ruled in favor of the petitioners, granting the writs of certiorari and prohibition. The Court annulled the orders of the respondent Judge and dismissed the civil case before him. The legal logic is firmly rooted in the doctrine of exclusive jurisdiction of the Bureau of Customs over seizure and forfeiture proceedings. The Court emphasized that the Collector of Customs possesses exclusive original jurisdiction over such cases pursuant to the Revised Administrative Code. This exclusive authority precludes regular courts, including Courts of First Instance, from interfering with or reviewing the Collector’s actions while the administrative proceedings are pending.
The Court, citing precedents like Ponce Enrile v. Vinuya and Luna v. Pacis, held that the proper remedy for an aggrieved party is to exhaust the administrative appellate hierarchy—appealing first to the Commissioner of Customs and then to the Court of Tax Appeals—as provided by law ( Republic Act No. 1125 ). Since an adequate and speedy remedy by appeal was available, the extraordinary writs of certiorari and prohibition were not proper remedies in the lower court. Consequently, Judge Geronimo acted without jurisdiction in taking cognizance of the case and in issuing the injunctive writs, which unduly interfered with the exclusive administrative process. The Supreme Court made permanent its own preliminary injunction against the enforcement of the lower court’s orders.