GR 157591; (December, 2005) (Digest)
G.R. No. 157591 December 16, 2005
ANTONIO CHUA, JR. and CARLOS CARILLO, Petitioners, vs. COMMISSIONER TITUS VILLANUEVA, DISTRICT COLLECTOR MARCIAL LOPEZ, DEPUTY COLLECTOR WINSTON FLORIN, COLLECTOR ROSALINO MARAVILLO, THE BUREAU OF CUSTOMS, P/SUPT. REYNALDO S. RAFAL, P/CHIEF INSP. NILO S. BERDIN, PHILIPPINE NATIONAL POLICE CMDR. CIRILO C. ORTIZ, CAPT. NILO C. FLORES and the PHILIPPINE COAST GUARD, Respondents.
FACTS
Petitioners Antonio Chua, Jr. and Carlos Carillo imported 35,000 bags of rice via the vessel M/V Criston, which docked at the Port of Tabaco, Albay. Upon arrival, Customs Commissioner Titus Villanueva, having been informed the vessel lacked a departure clearance, verbally ordered the issuance of a Warrant of Seizure and Detention (WSD). Deputy Collector Winston Florin issued WSD No. 06-2001, explicitly stating that based on submitted documents, he could “not find any violation” of the Tariff and Customs Code but issued the warrant in compliance with the Commissioner’s order, reserving the right to amend it should a violation later arise.
Petitioners filed a Petition for Prohibition with a prayer for a Temporary Restraining Order (TRO) before the Regional Trial Court (RTC) of Tabaco, Albay, assailing the WSD as invalid for lacking a factual basis and alleging grave abuse of discretion. The RTC initially issued a 72-hour TRO and, upon petitioners posting a bond, released the rice cargo. However, after the Bureau of Customs filed a Motion to Dismiss on jurisdictional grounds, the RTC ultimately dismissed the petition, citing the exclusive jurisdiction of the Bureau over seizure and forfeiture proceedings. The Court of Appeals affirmed this dismissal.
ISSUE
Whether the Regional Trial Court has jurisdiction to entertain a petition for prohibition questioning the validity of a Warrant of Seizure and Detention issued by the Bureau of Customs.
RULING
No, the Regional Trial Court has no jurisdiction. The Supreme Court affirmed the dismissal, holding that jurisdiction over seizure and forfeiture proceedings is vested exclusively in the Bureau of Customs by Section 602 of the Tariff and Customs Code. The legal logic is that the Collector of Customs, sitting in such proceedings, has exclusive authority to hear and determine all questions touching on the seizure and forfeiture of dutiable goods. This exclusivity is a settled doctrine designed to prevent delays in the government’s collection of revenues and to uphold the expertise of the customs bureau. Regular courts are precluded from interfering through petitions for certiorari, prohibition, or mandamus, even if the seizure is alleged to be illegal. Any challenge to the validity of the seizure, including the propriety of the WSD, must be raised as a defense within the administrative proceedings before the Bureau of Customs itself, with recourse available through the proper appellate chain to the Court of Tax Appeals and then the Supreme Court. The RTC’s initial assumption of jurisdiction was therefore a grave error.