GR L 18291; (January, 1964) (Digest)
G.R. No. L-18291; January 31, 1964
PHILIPPINES INTERNATIONAL SURETY COMPANY, INC., petitioner, vs. COMMISSIONER OF CUSTOMS, respondent.
FACTS
Seven cases of candy consigned to Manuel Santos arrived at the Port of Manila in December 1954. The shipment lacked required Central Bank release certificates and consular invoices, prompting the Collector of Customs to initiate seizure proceedings. During these proceedings, the merchandise was released to the consignee, Santos, after petitioner Philippine International Surety Co., Inc., posted a surety bond guaranteeing payment of the merchandise’s appraised value based on the seizure case’s outcome.
On April 30, 1955, the Collector of Customs rendered a decision ordering the forfeiture of the candy. The decision explicitly stated that since the goods were released under the surety bond, the claimant was required to pay the bond amount of P1,785.05, and if unpaid, action would be filed in court for collection. Copies of this decision were furnished to both Santos and the petitioner surety company on October 4, 1955. Manuel Santos appealed this decision to the Commissioner of Customs, but the petitioner surety company did not.
ISSUE
Whether the petitioner surety company, which failed to appeal the Collector of Customs’ decision to the Commissioner of Customs, retained the legal capacity to file a petition for review with the Court of Tax Appeals after the Commissioner affirmed the forfeiture.
RULING
The Supreme Court ruled that the petitioner lost its standing to appeal. The legal logic is anchored on the finality of administrative decisions and the surety’s status as a party to the proceedings. The Collector’s decision of April 30, 1955, which held the surety jointly and severally liable with the principal for the bond amount, was a definitive ruling against the petitioner. As the Court emphasized, the petitioner expressly admitted it became a party to the seizure proceedings from the moment it posted the bond, which was accepted as a substitute for the seized goods.
Since the petitioner was duly notified of this adverse decision but failed to perfect an appeal to the Commissioner of Customs as required under Section 1380 of the Revised Administrative Code, the decision became final and executory as to it. The subsequent appeal by the principal, Manuel Santos, did not benefit the surety; the Commissioner’s affirmance bound the surety as well. Consequently, having allowed the Collector’s decision to become final, the petitioner could not later seek recourse via a petition for review with the Court of Tax Appeals under Republic Act No. 1125 . The Court of Tax Appeals correctly dismissed the petition for lack of legal capacity to sue, a resolution the Supreme Court affirmed.