G.R. No. L-23504 December 29, 1967
ALBERTO DE JOYA, as Acting Commissioner of Customs (vice Jose B. Lingad) and PEDRO PACIS, as Acting Collector of Customs, petitioners, vs. JUAN T. DAVID and the HONORABLE COURT OF APPEALS, respondents.

FACTS

On May 28, 1962, a shipment of thirty-six crates, misdeclared as “stone grinders,” arrived in Manila. Without the required customs permit, the cargo was unloaded shipside onto a barge. A combined police and customs team intercepted the barge and found the crates contained highly dutiable goods like cigarettes and textiles. The goods, along with the lighter and tugboat, were seized for alleged violations of the Tariff and Customs Code. A criminal case was also filed against fifteen persons. Atty. Juan T. David appeared as counsel for the alleged shipper and consignee in the seizure proceedings. After the government presented its evidence, David moved to dismiss, but the Acting Collector of Customs deferred resolution. David then filed an ex parte motion for the release of the shipment under bond, claiming the goods were for transshipment to Singapore and some were perishable. The Collector denied the motion, noting the claim was not satisfactorily established and steps were taken to auction perishable items. David’s motion to dismiss was later denied. Subsequently, David filed Civil Case No. 56533 in the Court of First Instance of Manila against the customs officials, seeking a preliminary injunction to restrain the seizure proceedings, a mandatory injunction to surrender the cargo for transshipment, and damages. The trial court dismissed the case for lack of jurisdiction. David appealed to the Court of Appeals (CA-G.R. No. 34220-R). In the appellate court, David filed a motion for release of the cargo or for a writ of preliminary mandatory injunction. Without hearing the respondents, a Division of the Court of Appeals issued a resolution on September 7, 1964, stating that upon filing a P5,000 bond, a writ of preliminary injunction would be issued. The writ was issued on September 8, 1964. The Solicitor General, unaware of the resolution, filed an opposition. Upon notice, the Solicitor General filed an urgent motion to hold the writ in abeyance. The petitioners (customs officials) then filed the present original action for certiorari and prohibition with this Court to dissolve the Court of Appeals’ writ and restrain it from hearing the appeal. This Court issued a resolution restraining the Court of Appeals.

ISSUE

Whether the Court of First Instance of Manila and, consequently, the Court of Appeals on appeal, had jurisdiction over Civil Case No. 56533, which sought to obtain possession of goods subject to seizure and forfeiture proceedings before the Collector of Customs.

RULING

No. The Court of First Instance of Manila had no jurisdiction over the subject matter of Civil Case No. 56533, and the Court of Appeals had no jurisdiction over the appeal. The Supreme Court held that the jurisdiction of the Collector of Customs in seizure and forfeiture proceedings is exclusive. The Tariff and Customs Code vests in the Collector of Customs the authority to hear and decide such cases, with appeals going to the Commissioner of Customs and then to the Court of Tax Appeals. Allowing a Court of First Instance to exercise jurisdiction in an action for recovery of property subject to forfeiture proceedings would encroach upon and render futile the Collector’s jurisdiction. This is based on public policy to prevent forfeiture actions from being undermined by replevin. The judicial recourse for a property owner is to the Court of Tax Appeals only after exhausting administrative remedies in the Bureau of Customs. Furthermore, the Court of Appeals had no appellate jurisdiction because the jurisdiction of the trial court was in issue and the amount in controversy exceeded P200,000.00, placing the appeal within the exclusive appellate jurisdiction of the Supreme Court. The charge of contempt against the petitioners was dismissed. The writ of preliminary injunction issued by the Court of Appeals was nullified, and the preliminary injunction issued by the Supreme Court was made permanent.