GR 128064; (March, 2004) (Digest)
G.R. No. 128064; March 4, 2004
R.V. MARZAN FREIGHT, INC., petitioner, vs. COURT OF APPEALS and SHIELA’S MANUFACTURING, INC., respondents.
FACTS
Shiela’s Manufacturing, Inc. imported raw materials which arrived in April 1989. The Bureau of Customs withheld release due to unpaid taxes, and the consignee failed to file the required import entry. Sea-Land Service, Inc. subsequently authorized petitioner R.V. Marzan Freight, Inc., a customs-bonded warehouse operator, to take custody of the shipment for stripping and safekeeping. The District Collector of Customs initiated abandonment proceedings, posting a notice on September 29, 1989, as the consignee’s address was unknown. The declaration of abandonment became final on October 30, 1989. Before a public auction could be held, a fire destroyed the warehouse and the goods on July 26, 1990. Philippine Fire and Marine Insurance Corp. (Philfire), the warehouse insurer, paid Shiela’s Manufacturing P12 million. Shiela’s later sued Marzan for the goods’ value, claiming the goods were merely stored due to customs problems.
ISSUE
Whether Shiela’s Manufacturing retained ownership of the goods and had a valid cause of action for damages against the bonded warehouse operator at the time of the loss.
RULING
The Supreme Court ruled in favor of Marzan and dismissed the complaint. The legal logic centers on the effect of abandonment proceedings under the Tariff and Customs Code. Upon the consignee’s failure to claim the goods and file the requisite entry, the District Collector properly initiated abandonment proceedings. The posted notice complied with legal requirements. The declaration of abandonment became final and executory on October 30, 1989. By operation of law, the government ipso facto became the owner of the abandoned goods from that date. Consequently, at the time of the fire in July 1990, Shiela’s Manufacturing had already lost all ownership rights and interests in the cargo. Having no proprietary interest, it was not the real party-in-interest entitled to sue for damages against the warehouse custodian. The payment by Philfire to Shiel’s did not validate its claim, as such payment could not confer a right that had already been extinguished by law. The trial court lacked jurisdiction over the subject matter, as the determination of ownership was a customs administration matter conclusively settled by the final declaration of abandonment.