G.R. No. 138081 ; March 30, 2000
THE BUREAU OF CUSTOMS (BOC) and THE ECONOMIC INTELLIGENCE AND INVESTIGATION BUREAU (EIIB), petitioners, vs. NELSON OGARIO and MARK MONTELIBANO, respondents.

FACTS

On December 9, 1998, the District Collector of Customs of Cebu issued a Warrant of Seizure and Detention against 25,000 sacks of rice, based on a report from the EIIB that the rice was illegally imported. The goods, which arrived in Cebu aboard M/V “Alberto,” were alleged to have been originally landed in Palawan by a foreign vessel before being repacked and shipped domestically. Forfeiture proceedings were subsequently commenced before the Bureau of Customs.
The following day, respondents Mark Montelibano (the consignee) and Nelson Ogario (the buyer) filed a complaint for injunction with the Regional Trial Court (RTC) of Cebu City. They argued that the seizure was based merely on suspicion, as they possessed documents like a National Food Authority certification and a bill of lading indicating the rice was of domestic origin from Palawan. They sought to quash the warrant, restrain the customs authorities from proceeding, and recover damages, alleging irreparable injury from the detention of the perishable goods.

ISSUE

Whether the Regional Trial Court has jurisdiction to enjoin the forfeiture proceedings being conducted by the Bureau of Customs.

RULING

No. The Supreme Court reversed the Court of Appeals and ordered the dismissal of the RTC case. The Court reiterated the settled doctrine that the Bureau of Customs has exclusive jurisdiction over seizure and forfeiture proceedings under the Tariff and Customs Code. This jurisdiction is vested exclusively in the Collector of Customs, and regular courts are barred from interfering with or stifling the exercise of this authority.
The legal logic is clear: the exclusive administrative jurisdiction of the Bureau of Customs over such matters is a statutory principle designed for expediency and expertise. Even if the seizure is alleged to be tainted with illegality or grave abuse of discretion, the RTC is not the proper forum for relief. The law provides a complete administrative appellate remedy—an appeal from the Collector’s decision to the Commissioner of Customs, then to the Court of Tax Appeals, and ultimately to the Supreme Court via a petition for review. Allowing RTC injunctions would undermine this established process, cause disorder, and delay the efficient collection of customs revenues. The Court emphasized the need for strict adherence to this rule, citing a prior administrative circular cautioning judges against indiscriminately issuing restraining orders in customs cases.