G.R. No. L-10240; November 20, 1915
THE MANILA RAILROAD COMPANY, plaintiff-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellant.

FACTS:
The Manila Railroad Company imported 17,498 kilos of cast-iron brake blocks (brake shoes) into the Philippine Islands. The Insular Collector of Customs assessed the duty under subparagraph (b) of Paragraph 26 of the Philippine Tariff Act of 1909, which imposes a duty of 75 cents per 100 kilos on “other” articles of cast iron not specifically enumerated. The plaintiff protested, arguing that the brake blocks should be classified under subparagraph (a) of Paragraph 31 of the same Act, which imposes a duty of 45 cents per 100 kilos on “brake shoes” and similar railway articles made of wrought iron or steel. The Collector overruled the protest. On appeal, the Court of First Instance reversed the Collector, applying the doctrine of eo nomine (specific designation) and ordering the brake blocks to be assessed under Paragraph 31(a). The Insular Collector of Customs appealed to the Supreme Court.

ISSUE:
Whether cast-iron brake blocks should be classified for tariff purposes under Paragraph 26(b) (articles of cast iron) or Paragraph 31(a) (wrought iron or steel brake shoes) of the Tariff Act of 1909.

RULING:
The Supreme Court REVERSED the decision of the Court of First Instance and AFFIRMED the classification by the Insular Collector of Customs. The Court held that the cast-iron brake blocks must be classified under Paragraph 26(b) as articles of cast iron, not under Paragraph 31(a) which specifically covers wrought iron or steel articles.

The Court rejected the application of the eo nomine doctrine in this instance, reasoning that the brake blocks are made of cast iron, a material distinctly classified under Group 2 of the Tariff Act, while Paragraph 31(a) falls under Group 3 covering wrought iron and steel. To classify cast-iron articles under a provision for wrought iron or steel simply because the article name (“brake shoes”) appears there would lead to absurd results (e.g., rubber brake shoes being classified as wrought iron). The correct basis for classification is the material composition of the article, especially when a specific group exists for that material. Since the brake blocks are cast iron and not specifically listed in Paragraph 26(a), they properly fall under the residual category “other” in Paragraph 26(b).