G.R. No. L-19597. July 31, 1962.
CESAR CLIMACO, as Commissioner of Customs and TEOTIMO ROJA, as Collector of Customs of the Port of Manila, petitioners, vs. THE HON. JUDGE MANUEL P. BARCELONA and AUYONG HIAN, respondents.

FACTS

Respondent Auyong Hian imported approximately 600 hogsheads of Virginia leaf tobacco, which arrived at the Port of Manila on December 30, 1961. He sought entry and release of the shipment, presenting import control licenses (Nos. 17166, 17169, 17196, and 17199) issued by the defunct Import Control Commission on May 8, 1953, under Republic Act No. 650 (the Import Control Law). He claimed that, under Section 7 of R.A. No. 650 , the Bureau of Customs had a ministerial duty to allow entry of goods covered by such valid licenses. The Customs authorities refused to release the importation. Auyong Hian then filed a petition in the Court of First Instance of Manila, praying for a writ of preliminary mandatory injunction to compel the Customs officials to allow entry and release upon payment of duties.
The petitioners, Commissioner and Collector of Customs, opposed the issuance of the writ. They argued that the Court of First Instance lacked jurisdiction to order the release of property under customs custody. They contended that the Import Control Law ( R.A. No. 650 ) and the Commission that issued the licenses had ceased to exist on June 30, 1953. The governing law at the time of importation (December 1961) was Republic Act No. 1194 , which strictly limited the importation of Virginia leaf tobacco to legitimate manufacturers of Virginia-type cigarettes, subject to Central Bank allocation and a certification of insufficient local production—conditions Auyong Hian did not meet.

ISSUE

Whether the Court of First Instance acted with grave abuse of discretion in issuing a writ of preliminary mandatory injunction ordering the Customs authorities to allow entry and release of the imported Virginia leaf tobacco.

RULING

Yes, the Court of First Instance committed grave abuse of discretion. The Supreme Court granted the petition for certiorari, set aside the lower court’s order and the writ of injunction, and ordered the dismissal of the civil case.
The legal logic is anchored on the expiration and supersession of the applicable laws. The import control licenses were issued in 1953 under R.A. No. 650 , which expressly provided for its own expiration on June 30, 1953. The licenses, therefore, lost their legal efficacy upon the law’s termination and could not be revived or extended by mere executive approval. At the time of the actual importation in December 1961, the operative law was R.A. No. 1194 , which embodied a distinct national policy to protect the local tobacco industry. This law prohibited the importation of Virginia leaf tobacco except under stringent conditions: importation was allowed only to legitimate cigarette manufacturers, based on Central Bank allocation, and contingent upon a certification of insufficient local production. Respondent Auyong Hian failed to qualify under any of these conditions. Consequently, the importation was illegal from its inception. The Customs officials were therefore correct in refusing entry, and their actions constituted a lawful exercise of their jurisdiction. The lower court’s injunction, which interfered with this lawful customs proceeding, was issued without legal basis and in excess of jurisdiction. The Court emphasized that the alleged presidential approval of the licenses could not legalize an importation expressly prohibited by a subsequent statute.