G.R. No. 216634 & 216636, October 14, 2020
HON. PAQUITO N. OCHOA, JR., ET AL. AND SANYO SEIKI STAINLESS STEEL CORPORATION, PETITIONERS, VS. ATTY. CHRISTOPHER S. DY BUCO, RESPONDENT.

FACTS

The Bureau of Customs (BOC) Commissioner issued Letters of Authority (LOAs) and Mission Orders authorizing the Run-After-The-Smugglers (RATS) Group, including Atty. Christopher S. Dy Buco, to inspect the warehouses of Sanyo Seiki Stainless Steel Corporation for possible smuggled goods. The RATS Group, with police assistance, attempted to serve the orders but were denied entry into the premises. Subsequently, the group intercepted a delivery truck leaving a Sanyo Seiki warehouse. The driver failed to present proof of payment of duties and taxes for the steel products, leading to the issuance of a Warrant of Seizure and Detention.
Sanyo Seiki filed a complaint with the Office of the President (OP). The OP found Atty. Dy Buco and other RATS members guilty of Grave Misconduct, Grave Abuse of Authority, Oppression, Gross Incompetence, and Conduct Prejudicial to the Best Interest of the Service, ordering their dismissal. The Court of Appeals (CA) reversed the OP’s decision, dismissing the complaint. The petitioners, including the government officials and Sanyo Seiki, elevated the case to the Supreme Court via petitions for review.

ISSUE

Whether the Court of Appeals erred in reversing the finding of administrative liability against Atty. Christopher S. Dy Buco.

RULING

The Supreme Court denied the petitions and affirmed the CA’s decision. The Court held that the RATS Group, including Atty. Dy Buco, acted within their legal authority under Section 2536 of the Tariff and Customs Code, which allows customs officers to demand evidence of duty payment on foreign articles offered for sale or stored. The issuance of the LOAs and Mission Orders by the Commissioner provided prior authorization, a statutory prerequisite. The subsequent seizure of the truck and cargo was a valid exercise of this power after the driver failed to produce the required documents.
The Court found no substantial evidence to support the administrative charges. The acts complained of—attempting to inspect the warehouses and seizing the truck—were performed in the regular course of official duty pursuant to a valid mission. There was no proof of malice, bad faith, or willful intent to violate the law or disregard established rules. Mere errors in judgment, if present, are not tantamount to administrative misconduct absent a showing of corrupt motive. The OP’s findings were based on misapprehension of facts, and the CA correctly ruled that the actions taken were justified under the customs laws.