GR 27693; (January, 1971) (Digest)
G.R. No. L-27693. January 29, 1971. RAMCAR, INC., plaintiff-appellant, vs. RAFAEL SUMADCHAT, operator of the R. Sumadchat Custom Bonded Warehouse No. 258, defendant-appellee.
FACTS:
Ramcar, Inc. imported a shipment of lead ingots which arrived at the Port of Manila. Without Ramcar’s knowledge or consent, 601 of these ingots were taken and stored in the customs bonded warehouse operated by Rafael Sumadchat. Upon demand by Ramcar for the delivery of the ingots, Sumadchat refused and instead demanded payment for storage and other charges. Ramcar filed a complaint in the Court of First Instance of Manila, praying that Sumadchat be ordered to deliver the ingots or pay their value.
Sumadchat moved to dismiss the complaint. He asserted that, upon importation, the ingots fell under the exclusive possession, custody, and control of the Bureau of Customs pursuant to the Tariff and Customs Code. He further alleged that the Bureau had subsequently declared the ingots abandoned, sold them at public auction to a third party, Marcelo S. Cruz, and authorized their release to him. The trial court granted the motion and dismissed the complaint without prejudice to Ramcar filing an action against the proper party.
ISSUE
Whether the trial court correctly dismissed Ramcar’s complaint for failure to state a cause of action against the defendant-appellee, Rafael Sumadchat.
RULING
Yes, the dismissal was proper. The Supreme Court affirmed the order of the trial court. The legal logic is anchored on the statutory authority and exclusive jurisdiction of the Bureau of Customs over imported goods. Under Republic Act No. 1937, the Tariff and Customs Code, the Bureau exercises exclusive possession, custody, control, and disposition over all articles imported into the Philippines until the lawful duties and charges are paid. The ingots were stored in the defendant’s warehouse not by private contract but because the warehouse was a customs-bonded facility subject to the Bureau’s control and management.
Crucially, the defendant’s actions concerning the goods—their storage and subsequent release—were performed under the authority and by order of the Bureau of Customs. The Bureau validly exercised its functions by declaring the goods abandoned and selling them at public auction. Since there was no direct contractual relationship between Ramcar and Sumadchat, and Sumadchat was merely acting as an agent or instrumentality of the Bureau in holding the goods, Ramcar had no cause of action against him. Any claim for the value of the ingots should be directed against the Bureau of Customs or the proper government agency, not the warehouseman who acted under its directive. The appeal was devoid of merit.