GR L 13472; (January, 1919) (Digest)
G.R. No. L-13472; January 20, 1919
FRANK J. WOODWARD, plaintiff-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, defendant-appellant.
FACTS:
Frank J. Woodward arrived at the port of Manila on May 15, 1917, with his family, bringing his household and personal effects, including a motor boat. His intention was to settle in Cagayan de Misamis, Mindanao, where he actually took station as a missionary. The motor boat was for his personal use in transportation between Cagayan de Misamis and surrounding areas and was not intended for barter or sale. The Insular Collector of Customs assessed import duty on the motor boat under Section 8, paragraph 200 of the Philippine Tariff Act of 1909, which imposes a 50% ad valorem duty on imported watercraft. Woodward contested this, claiming the motor boat should be admitted free of duty as part of his “personal and household effects” under paragraph 338 of the same Act, which grants duty-free admission for such items belonging to persons coming to settle in the Philippines.
ISSUE:
Whether a motor boat, brought into the Philippines by a settler for his personal use and not for sale, is subject to import duty as a watercraft under paragraph 200, or is exempt as “personal and household effects” under paragraph 338 of the Philippine Tariff Act of 1909.
RULING:
The Supreme Court ruled in favor of Woodward, affirming the lower court’s decision. The motor boat is exempt from duty as part of his “personal and household effects.” The Court, citing U.S. Supreme Court precedent in Arthur vs. Morgan, held that the term “household effects” in tariff laws is not limited to items used within a house but includes articles that contribute to the convenience and welfare of a household, such as carriages. Analogizing the motor boat’s function for water transportation to that of a carriage or vehicle for land transportation, the Court found it to be of a similar character and purpose. Since the Tariff Act of 1909 did not restrict “household effects” to items similar to furniture or books (as a later U.S. law did), the motor boat qualified for duty-free admission under paragraph 338 as a bona fide personal effect brought by a settler for his own use. The judgment ordering its free admission was affirmed.