G.R. No. L-11860; May 29, 1959
COMMISSIONER OF CUSTOMS, petitioner, vs. LT. COL. LEOPOLDO RELUNIA, respondent.

FACTS

On December 10, 1953, the RPS “MISAMIS ORIENTAL,” a Philippine Navy vessel, was dispatched to Japan and Korea for official duties. It returned to the Philippines on September 2, 1954, carrying 180 cases of various articles subject to customs duties. These articles were classified into three groups: those for the Philippine Army Post Exchange, those for the Philippine Navy Officers Base Commissary, and those belonging to individuals, including an electric range consigned to respondent Lt. Col. Leopoldo Relunia. The Collector of Customs declared all articles forfeited for violations of the Customs Law, specifically under Section 1363(g) of the Revised Administrative Code, for being unmanifested cargo. The Commissioner of Customs affirmed this decision. The Court of Tax Appeals reversed, ordering the release of the electric range to Relunia upon payment of duties, holding the forfeiture under Section 1363(g) illegal. The Commissioner of Customs appealed this decision to the Supreme Court.

ISSUE

Whether the RPS “MISAMIS ORIENTAL” was required under the Customs Law to submit a cargo manifest upon its arrival from a foreign port, and consequently, whether the electric range was subject to forfeiture as unmanifested merchandise under Section 1363(g) of the Revised Administrative Code.

RULING

The Supreme Court reversed the decision of the Court of Tax Appeals and reinstated the forfeiture order of the Commissioner of Customs.
The Court held that all vessels, whether private or government-owned, including Philippine Navy ships, arriving from a foreign port are required to prepare and present a cargo manifest to customs authorities, with the exception of war vessels or vessels employed by any foreign government not engaged in the transportation of merchandise in the way of trade, as provided in the second paragraph of Section 1221 of the Revised Administrative Code. The RPS “MISAMIS ORIENTAL” did not fall under this exception because it was transporting merchandise, including the electric range consigned to a private individual.
The Court found that Sections 1221, 1225, and particularly 1228 of the Revised Administrative Code impose a universal requirement for a manifest on every vessel from a foreign port. Section 1228 explicitly states: “Every vessel from a foreign port or place must have on board complete written or typewritten manifests of all her cargo.” The purpose of the manifest is to prevent smuggling and surreptitious activities. The Court rejected the Tax Court’s reliance on the title “Entrance of vessels in foreign trade” for Article VI of the Customs Law, stating that resort to a statute’s title is an unsafe criterion and is unnecessary where the law’s meaning is clear.
The evidence indicated that no proper cargo manifest was ever delivered to the customs authorities for the vessel’s cargo. Therefore, the electric range, as unmanifested merchandise found on a vessel for which a manifest was required, was correctly forfeited under Section 1363(g). The decision of the Court of Tax Appeals was set aside, and the decision of the Commissioner of Customs was affirmed.