G.R. No. L-10386; October 26, 1915

FACTS:
The plaintiff-appellee, Te Chin Boo, imported certain goods, wares, and merchandise into the Philippine Islands. The Insular Collector of Customs appraised the value of these imported articles. Te Chin Boo protested this appraisement. The Collector of Customs disallowed the protest. Te Chin Boo then appealed to the Court of First Instance. The judge of the Court of First Instance heard testimony regarding the wholesale value of the merchandise and subsequently rendered a judgment reversing the findings of the Collector of Customs. The court ordered the record returned with a direction for the Collector to fix the value in accordance with the declarations of the protestant, Te Chin Boo. The Collector of Customs appealed this decision to the Supreme Court.

ISSUE:
Whether the Court of First Instance can review and overturn the appraisement of imported merchandise made by the Collector of Customs based solely on a discrepancy in the valuation, without a showing that the Collector proceeded upon a wrong principle or acted contrary to law.

RULING:
The Supreme Court reversed the judgment of the Court of First Instance. The Court held that the valuation of imported merchandise fixed by the customs authorities (the appraiser and confirmed by the Insular Collector of Customs) is conclusive and final. This valuation cannot be overturned by a court merely upon proof that the value fixed was not the real or correct value. For a court to review and set aside such an appraisement, there must be an affirmative showing that the Collector of Customs, in fixing the value, proceeded upon a wrong principle and acted contrary to law. In this case, no such showing was made; the evidence only tended to show a difference in opinion on the actual value. The Supreme Court cited established precedents from both Philippine jurisprudence (e.g., Lim Quim vs. Collector of Customs) and United States Supreme Court decisions supporting this principle. The judgment of the Court of First Instance was revoked. No costs were awarded.