G.R. No. L-31642 October 28, 1977
The COMMISSIONER OF CUSTOMS, the DEPUTY COMMISSIONER OF CUSTOMS and the COLLECTOR OF CUSTOMS of Manila, petitioners, vs. Honorable FRANCISCO GERONIMO, in his capacity as Judge of the Court of First Instance of Manila, Branch XII, and RAFAEL CASTRO, JR., respondents.

FACTS

Acting Commissioner of Customs Juan Ponce Enrile, during an inspection at Manila Port on May 17, 1967, discovered packages unmanifested on the SS “President Wilson” containing luxury items, including 791 rolls of jusi material. The Collector of Customs seized the goods for violation of the Tariff and Customs Code. After proper notice via posting and a hearing where no claimants appeared, the Collector, on June 23, 1967, ordered the forfeiture of all items in favor of the State in Seizure I.D. No. 10747. Months later, Natividad Velasco (assignor of respondent Rafael Castro, Jr.) and Maria Azurin separately filed petitions for relief, each claiming specific quantities of the jusi rolls (125 and 120 rolls, respectively). Their petitions were initially denied by the Collector. However, the Commissioner of Customs later reversed the Collector on Velasco’s appeal, leading the Collector on June 4, 1968, to order the release of 125 rolls to Velasco, who waived her right to appeal. Meanwhile, Azurin also appealed to the Commissioner, who on March 19, 1969, ruled in her favor, ordering the release of 120 rolls. The jusi rolls had been commingled, and only 120 rolls remained in custody. Castro, seeking to enforce the Collector’s decision in his assignor’s favor, filed a mandamus action in the Court of First Instance. The respondent Judge ruled that the Collector’s June 4, 1968, decision was final and must be executed, preventing the Commissioner from modifying it.

ISSUE

Whether the Court of First Instance correctly granted mandamus to enforce the Collector of Customs’ June 4, 1968 decision ordering the release of jusi material, despite the original forfeiture proceeding having attained finality.

RULING

The Supreme Court reversed the decision of the Court of First Instance. The legal logic centers on the finality and validity of the original forfeiture proceeding (Seizure I.D. No. 10747). The Collector’s initial forfeiture order of June 23, 1967, was rendered after compliance with statutory requirements: the goods were unmanifested, notices were posted for unknown owners, and no claims were filed at the hearing. This judgment in favor of the State became final. The subsequent decisions by the Collector and Commissioner, which granted relief to Velasco and Azurin, were issued without jurisdiction. The claimants’ use of “baggage” declarations for large commercial quantities of jusi material (worth approximately P50,000 and P48,000) was a subterfuge, as these were clearly undeclared cargo, not legitimate passengers’ baggage. The original forfeiture was thus valid and could not be lawfully set aside. The respondent Judge committed grave abuse of discretion by enforcing the later, void decision of the Collector instead of recognizing the final forfeiture. The Supreme Court directed the customs officials to dispose of the remaining 120 rolls of jusi as goods finally forfeited to the State.