G.R. No. 94996 January 26, 2001
ALEMAR’S (SIBAL & SONS), INC., petitioner, vs. THE HONORABLE COURT OF APPEALS, RAMON FAROLAN, BIENVENIDO P. ALANO, JR., SENEN DIMAGUILA, COSME B. SEKITO, JR., MANUEL DIONALDO, in their official capacity/ies, as Commissioner, Customs Collector District II; Customs Collector, Manila International Container Port; Chief, Auction and Cargo Disposal Division; Chief, Law Division, respectively of The Bureau of Customs, Arrastre Contractor MIPTI, and LUIS CUA, respondents.

FACTS

Petitioner Alemar’s imported books and supplies in November 1983. The shipment was placed under Bureau of Customs custody. Despite becoming the consignee’s agent in November 1984, Alemar’s application for an import entry was denied because the goods had been declared abandoned in Abandonment Proceedings No. 84-854. The required notice of this declaration was never sent to Alemar’s or the bank. Upon learning of a potential abandonment, Alemar’s filed a letter on December 12, 1984, expressly stating it had no intention to abandon the shipment. Nonetheless, the Auction Division proceeded with a public auction on December 20, 1984, where respondent Luis Cua was the highest bidder.
To prevent delivery to Cua, Republic Planters Bank and Alemar’s filed a petition with the Regional Trial Court (RTC) seeking to nullify the abandonment declaration and auction sale, arguing lack of due notice. The RTC dismissed the case for lack of jurisdiction. The Court of Appeals affirmed this dismissal, prompting Alemar’s appeal to the Supreme Court via certiorari.

ISSUE

Whether the Regional Trial Court had jurisdiction over the petition to annul the Collector of Customs’ declaration of abandonment and the subsequent public auction sale.

RULING

The Supreme Court denied the petition, ruling that the RTC correctly dismissed the case for lack of jurisdiction. The Court emphasized that jurisdiction is determined by the nature of the action as pleaded in the complaint. The core action was the annulment of the Collector of Customs’ act in declaring the importation abandoned and ordering its sale. This matter falls squarely within the exclusive jurisdiction of the Bureau of Customs over abandonment and forfeiture proceedings.
The legal logic is that the Tariff and Customs Code provides a complete administrative remedy for aggrieved parties. Dissatisfaction with a Collector’s decision must first be appealed to the Commissioner of Customs, whose decision is then appealable to the Court of Tax Appeals. Regular courts, including the RTC, are precluded from interfering with these proceedings, even through special civil actions like certiorari or prohibition. The Court found that Alemar’s failed to avail itself of this administrative hierarchy, having filed its entry attempt over a year after the goods’ arrival. Its direct recourse to the RTC was therefore fatal to its cause. The absence of notice, while raised as an issue, did not alter the fundamental principle of exclusive customs jurisdiction over such subject matter.