GR 104604; (October, 1995) (Digest)
G.R. No. 104604 & G.R. No. 111223. October 6, 1995.
NARCISO O. JAO and BERNARDO M. EMPEYNADO, petitioners, vs. COURT OF APPEALS, et al. (G.R. No. 104604) and THE HONORABLE OMBUDSMAN CONRADO M. VASQUEZ, et al. (G.R. No. 111223).
FACTS
Petitioners Jao and Empeynado filed a civil case for Injunction and Damages (Civil Case No. 90-2382) before the Regional Trial Court (RTC) of Makati. They sought to restrain customs officials from implementing Warrants of Seizure and Detention issued against allegedly untaxed vehicles and parts found on their premises in Makati and Parañaque. The RTC issued a Temporary Restraining Order and later a preliminary injunction, ordering the return of the seized items. Respondents moved to dismiss, arguing the RTC lacked jurisdiction over seizure and forfeiture proceedings, which fall under the exclusive jurisdiction of the Bureau of Customs. The RTC denied the motion.
Simultaneously, petitioners filed criminal complaints for Robbery and Violation of Domicile against the customs and police officers before the Office of the Ombudsman (OMB Case No. 0-90-2027). The Ombudsman dismissed the complaint, finding no prima facie case. The Court of Appeals, in G.R. No. 104604, granted the customs officials’ petition, set aside the RTC’s orders, and dismissed the civil case for lack of jurisdiction. Petitioners elevated both the CA decision and the Ombudsman’s dismissal to the Supreme Court via consolidated petitions for certiorari.
ISSUE
Whether the Regional Trial Court had jurisdiction to entertain the civil case for injunction and damages assailing the seizure proceedings conducted by the Bureau of Customs.
RULING
No. The Supreme Court dismissed both petitions, affirming the Court of Appeals and the Ombudsman. The Court held that seizure and forfeiture proceedings are within the exclusive jurisdiction of the Bureau of Customs, as provided by the Tariff and Customs Code. Regular courts are precluded from interfering with or restraining these proceedings through ancillary writs like injunction. The Collector of Customs, when conducting such proceedings, acts as a tribunal with exclusive authority to determine all matters related thereto, including the validity of the seizure.
The allegations of irregularity in the issuance or execution of the warrants—such as claims of defective warrants or violations of domicile—do not divest the Bureau of Customs of its jurisdiction. These are matters of defense that must be raised within the administrative forfeiture proceedings before the Collector of Customs, with recourse available through the proper appellate chain to the Court of Tax Appeals and eventually the Supreme Court. A separate civil action in the RTC is an improper remedy that undermines the doctrine of exhaustion of administrative remedies and the statutory grant of exclusive jurisdiction. Consequently, the RTC acted without jurisdiction in taking cognizance of the injunction case.