G.R. Nos. L-15381 and L-15382; April 26, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIA MAYDIN, defendant-appellant.

FACTS

The defendant-appellant, Maria Maydin, was an outgoing passenger bound for Hongkong on February 23, 1956. During a routine customs inspection at the Manila International Airport, examiner Benigno Layug questioned her about the money she was carrying. Maydin declared she only had $100 covered by a license and P100 in Philippine currency. However, upon inspection of her handbag, Layug found P400 in fifty-peso bills. When her overnight kit was examined, a false bottom was discovered. Maydin initially resisted further inspection but later admitted to Deputy Collector Crisostomo that the compartment contained about P10,000. She was allowed to depart after leaving her husband as a representative. The kit was opened, revealing P10,800 in Philippine currency and $40 in US dollars.
Two criminal cases were filed against Maydin. In Criminal Case No. 3825-P, she was charged with violating Central Bank Circular No. 42 for possessing $40 without the required license. In Criminal Case No. 3796-P, she was charged with violating Circular No. 60 for possessing P10,800 without the necessary permit. The Court of First Instance of Rizal found her guilty in both cases, imposing imprisonment, fines, and forfeiture of the currencies. Maydin appealed, and the Court of Appeals certified the cases to the Supreme Court, raising purely legal questions.

ISSUE

The primary issues were: (1) whether the Central Bank needed to declare an “exchange crisis” before issuing the circulars; (2) whether Circular No. 20 and subsequent circulars (Nos. 42 and 60) required presidential approval for validity; and (3) whether Maydin’s oral declaration to customs officials could substitute for the required Central Bank license or permit.

RULING

The Supreme Court affirmed the convictions. On the first issue, the Court ruled that no prior declaration of an exchange crisis was necessary for the Central Bank to exercise its powers under Republic Act No. 265 . The circulars were valid exercises of authority to carry out the law’s objectives, as consistently upheld in prior jurisprudence.
On the second issue, the Court held that Circular No. 20 had the requisite presidential approval. Subsequent circulars, like Nos. 42 and 60, which merely implemented and supplemented Circular No. 20, did not require separate presidential approval. Their validity was thus sustained.
On the third issue, the Court found Maydin’s claim—that she orally declared the currencies to customs—untenable. The trial court found she initially declared only $100 and P100. Her subsequent admission, made only after detection, could not substitute for the formal license or permit mandated by law. The forfeiture of the currencies was also deemed legal, distinguishing this case from People vs. Lim Ho, as the bills here were presented in evidence and under the trial court’s control. The penalties imposed by the lower court were affirmed.