GR 165027; (October, 2006) (Digest)
G.R. No. 165027 ; October 12, 2006
PROTON PILIPINAS CORPORATION, petitioner, vs. REPUBLIC OF THE PHILIPPINES, represented by the BUREAU OF CUSTOMS, respondent.
FACTS
Petitioner Proton Pilipinas Corporation acquired Tax Credit Certificates (TCCs) worth over P30 million from Devmark Textile Industries, Inc. and Texasia, Inc. as payment for vehicles. The Deed of Assignment for the TCCs was conditionally approved by the Department of Finance (DOF). Proton subsequently used these TCCs to pay its customs duties and taxes to the Bureau of Customs (BOC). Later, an Ombudsman investigation revealed that the TCCs issued to Devmark were fraudulently obtained based on fake documents, leading to their cancellation. Consequently, the BOC filed a civil case for collection of unpaid customs duties against Proton before the Regional Trial Court (RTC). Proton moved to dismiss, arguing the RTC lacked jurisdiction, claiming such tax collection cases fell under the exclusive jurisdiction of the Court of Tax Appeals (CTA). The RTC denied the motion, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Regional Trial Court had jurisdiction over the civil case for collection of customs duties filed by the Bureau of Customs against Proton Pilipinas Corporation.
RULING
Yes, the RTC had jurisdiction. The Supreme Court ruled that at the time the BOC filed its collection case in 2002, the applicable law was Republic Act No. 1125 , as amended. Under this law, the CTA’s jurisdiction was appellate in nature over decisions of the Commissioner of Customs on matters involving customs duties. Original actions for the collection of unpaid customs duties, where the principal issue was the validity of the tax credit certificates used for payment, were not within the CTA’s exclusive original jurisdiction. Such collection cases initiated by the BOC were cognizable by the regular courts, specifically the RTC, pursuant to its general jurisdiction. The Court clarified that the expanded jurisdiction of the CTA under Republic Act No. 9282 , which grants it original jurisdiction over tax collection cases, took effect only on April 23, 2004, and does not apply retroactively to this case filed earlier. Therefore, the RTC correctly assumed jurisdiction over the collection suit.