GR 209830; (June, 2015) (Digest)
G.R. No. 209830 ; June 17, 2015
MITSUBISHI MOTORS PHILIPPINES CORPORATION, Petitioner, vs. BUREAU OF CUSTOMS, Respondents.
FACTS
The Bureau of Customs (respondent) filed a collection suit against Mitsubishi Motors Philippines Corporation (petitioner) before the Regional Trial Court (RTC) of Manila for unpaid taxes and customs duties amounting to ₱46,844,385.00. Respondent alleged that from 1997 to 1998, petitioner utilized Tax Credit Certificates (TCCs) to pay for import duties and taxes, but a post-audit revealed these TCCs were fraudulently secured using fake documents. Respondent demanded payment, and upon petitioner’s failure to pay, filed the complaint. Petitioner defended itself by claiming it acquired the TCCs in good faith and that they were authentic. After respondent presented its evidence, petitioner filed a Demurrer to Evidence. The RTC granted the demurrer and dismissed the case, finding respondent failed to prove fraud by clear and convincing evidence. Respondent appealed this dismissal to the Court of Appeals (CA).
ISSUE
Whether or not the Court of Appeals correctly referred the records of the tax collection case to the Court of Tax Appeals for proper disposition of the appeal taken by the Bureau of Customs.
RULING
No. The petition is meritorious. The Supreme Court ruled that the CA erred in referring the records to the CTA. Jurisdiction over the subject matter is conferred by law. Republic Act No. 1125 , as amended by R.A. No. 9282 , grants the CTA exclusive appellate jurisdiction over tax collection cases originally decided by the RTC. Since the CA had no jurisdiction over respondent’s appeal, its only power was to dismiss the action outright, as explicitly mandated by Section 2, Rule 50 of the Rules of Court. The CA’s act of referring the case under the guise of furthering substantial justice was blatantly erroneous; the invocation of substantial justice does not dispel the mandatory application of jurisdictional rules. Furthermore, respondent availed of the wrong mode of appeal by filing a notice of appeal to the CA instead of a petition for review to the CTA within the 30-day period prescribed by law. Consequently, the failure to perfect the appeal correctly rendered the RTC’s dismissal order final and executory. The Supreme Court reversed the CA Resolutions and dismissed the appeal of the Bureau of Customs to the CA.