G.R. No. 246343 . November 18, 2021.
THE BUREAU OF CUSTOMS AND THE COMMISSIONER OF CUSTOMS, PETITIONERS, VS. JADE BROS. FARM AND LIVESTOCK, INC., RESPONDENT.

FACTS

Jade Bros. Farm and Livestock, Inc. (JBFLI) entered into several rice importation transactions in 2013. Upon arrival at the Manila International Container Port (MICP), the Bureau of Customs (BOC) refused to release the shipments due to JBFLI’s alleged lack of an import permit from the National Food Authority (NFA). JBFLI filed a Petition for Declaratory Relief and Permanent Injunction before the Regional Trial Court (RTC) of Manila, arguing the import permit requirement had no legal basis. Simultaneously, during the pendency of the RTC case, JBFLI requested the MICP District Collector to lift alert orders on its shipments or issue Warrants of Seizure and Detention (WSDs). The District Collector issued WSDs, initiating seizure proceedings. JBFLI filed a Consolidated Motion for Release Under Cash Bond. The District Collector instead posted a Notice of Public Auction. JBFLI then filed a Petition for Review with the Court of Tax Appeals (CTA) to challenge the District Collector’s inaction on its motion and the scheduled auction. The CTA Third Division granted JBFLI’s petition, ordered the release of the shipments upon posting a cash bond, and declared the importations legal. The BOC’s motion for reconsideration was denied. The BOC appealed to the CTA en banc. The CTA en banc failed to muster the required votes to reverse the Division’s ruling, thus affirming it. The BOC and Commissioner of Customs then filed this Petition for Review on Certiorari.

ISSUE

Whether the CTA correctly assumed jurisdiction over JBFLI’s Petition for Review despite the pendency of a related case before the RTC involving the same parties and the core issue of the legality of the import permit requirement.

RULING

No, the CTA did not correctly assume jurisdiction. The Supreme Court granted the petition and reversed the CTA en banc resolutions. The Court held that the CTA should have dismissed JBFLI’s Petition for Review for lack of jurisdiction due to the doctrine of primary jurisdiction and the pendency of the RTC case. The core issue—the validity of the NFA import permit requirement—was a purely legal question involving the interpretation of statutes and administrative issuances, which was already pending before the RTC in a declaratory relief action. The BOC’s seizure proceedings were contingent upon the resolution of that legal issue. By taking cognizance of the case, the CTA Division effectively decided the very question pending before the RTC, violating the doctrine of primary jurisdiction and potentially causing conflicting rulings. The proper course of action for the CTA was to dismiss the petition and direct the parties to await the outcome of the RTC proceedings. The CTA’s jurisdiction over seizure cases is not exclusive and can yield when a related case involving the same fundamental issue is already pending before a court of general jurisdiction.