G.R. No. L-20676 February 26, 1965
ACTING COLLECTOR OF CUSTOMS TEOTIMO ROJA, petitioner, vs. DE LA RAMA STEAMSHIP CO., INC. and HON. FEDERICO C. ALIKPALA, in his capacity as Judge of the Court of First Instance of Manila, Branch XXII, respondents.

FACTS

Respondent De la Rama Steamship Co., Inc., operator of the foreign vessel s/s “Mentor,” had the vessel seized by the Collector of Customs of Manila on May 28, 1962, for conveying unmanifested cargo and discharging it shipside without authorization. The vessel was released upon a P10,000 bond. On May 30, 1962, the Collector imposed an administrative fine of P30,000 for violations of the Tariff and Customs Code. The company protested the fine in writing and requested a hearing. A hearing was scheduled but postponed; counsel for De la Rama allegedly did not receive timely notice and could not attend. The Collector reaffirmed the fine and denied reconsideration. The shipping company filed a notice of appeal to the Commissioner of Customs but was informed the appeal “cannot be given due course” based on a ruling that fines on vessels must be paid first, after which payment may be protested. Consequently, De la Rama Steamship Co. filed Civil Case No. 51824 in the Court of First Instance of Manila, seeking a declaration that the fine and denial of appeal were illegal, a permanent injunction against enforcement of the fine or seizure of the vessel, and an order for the Collector to grant a hearing. The Court of First Instance issued the injunction. The Collector moved to dismiss for lack of jurisdiction, and upon denial, sought relief in the Supreme Court.

ISSUE

Did the Court of First Instance of Manila have jurisdiction to entertain the action filed by De la Rama Steamship Co., Inc., to review and enjoin the Collector of Customs’ decision imposing an administrative fine?

RULING

No. The Supreme Court held that the Court of First Instance lacked jurisdiction. The action sought judicial review of the Collector of Customs’ decision, which violates the provisions of the Administrative Code (Section 1380) and Republic Act No. 1125 (the law creating the Court of Tax Appeals). Under Section 7, paragraph (2) of Republic Act No. 1125 , the Court of Tax Appeals has exclusive appellate jurisdiction to review decisions of the Commissioner of Customs on fines or matters arising under the Customs Law. The Court emphasized that courts of first instance cannot interfere with decisions of Customs authorities, even through petitions for mandamus or certiorari. The respondent’s argument that the Court of Tax Appeals could only review decisions of the Commissioner, and not the Collector, was untenable. The Commissioner has supervisory power to review decisions of the Collector under the Administrative Code. The respondent failed to exhaust administrative remedies by not complaining to the Commissioner about the Collector’s refusal to give due course to the appeal. Had the Commissioner sustained the Collector, the respondent could then have appealed to the Court of Tax Appeals. Therefore, the writs of certiorari and prohibition were granted. The respondent Court of First Instance was directed to refrain from proceeding with Civil Case No. 51824, and the preliminary injunction it issued was annulled and set aside. Costs were imposed on De la Rama Steamship Co., Inc.