G.R. No. L-32921-40. June 10, 1971.
ANDRES M. SENERES, as Collector of Customs for the Port of Iloilo, GIL B. ARMADA, as Acting Deputy Collector of Customs, and IRENEO HORTILLOSA, as Wharfinger, petitioners, vs. HON. VICENTE O. FRIAS, as Judge of the Court of First Instance of Iloilo, and various private respondents-consignees, represented by their Attorneys-in-Fact, respondents.

FACTS

The private respondents, forty consignees, imported forty crates declared as “used sheet containers” and “used sample wood panels.” Upon customs examination at the Port of Iloilo, the shipments were found to contain parts of slot and jackpot machines. The customs authorities refused to process the informal entries filed for the crates’ release, neither requiring additional documents nor accepting payment of purported duties, but also did not immediately institute seizure proceedings. Alleging this refusal to act and claiming the shipments were merely parts and not complete, prohibited gambling devices, the consignees, through common counsel, filed twenty separate petitions for mandamus with preliminary mandatory injunction in the Court of First Instance of Iloilo.
They prayed the court to compel the Collector of Customs to accept their self-computed duty payments and to order the shipments’ release. Without issuing summons or conducting a proper hearing, and upon an ex-parte application late on December 11, 1970, respondent Judge Vicente O. Frias issued an order on December 12, 1970, granting the writs of preliminary mandatory injunction. The judge reasoned that Section 102 of the Tariff and Customs Code, which prohibits the importation of gambling devices, might not cover mere parts, a matter he deemed proper for judicial interpretation. He ordered the release of the crates upon the filing of bonds.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain the petitions for mandamus and to issue the writ of preliminary mandatory injunction for the release of the imported articles held by customs authorities.

RULING

No. The Supreme Court annulled the respondent judge’s orders for lack of jurisdiction. The Court held that exclusive jurisdiction over seizure and forfeiture proceedings, including the detention and release of imported goods, is vested in the Collector of Customs, subject to review by the Commissioner of Customs and ultimately by the Court of Tax Appeals. The Bureau of Customs has exclusive authority to conduct searches, seizures, and investigations concerning customs laws. When goods are suspected to be of prohibited importation, as slot machine parts are under Section 102 of the Tariff and Customs Code, the Collector’s duty is to prevent their importation.
The CFI’s assumption of jurisdiction via mandamus was a clear usurpation of this exclusive administrative and quasi-judicial authority. The propriety of the importation—whether the items were prohibited parts or not—was a matter initially for the Collector to determine in a seizure proceeding, not for a regular court to preempt through injunction. The private respondents’ remedy was to await the Collector’s action and, if aggrieved, to appeal through the prescribed administrative and judicial review hierarchy. The Court emphasized that the rule of exhaustion of administrative remedies and the doctrine of primary jurisdiction are firmly established, preventing courts of first instance from interfering with customs administration. The writs of certiorari and prohibition were granted, making permanent the preliminary injunction previously issued by the Supreme Court restraining the CFI orders.