GR L 22977; (May, 1972) (Digest)
G.R. No. L-22977 May 31, 1972
COLLECTOR OF CUSTOMS, et al., petitioners, vs. HON. GUILLERMO E. TORRES, et al., respondents.
FACTS
A shipment of 158 packages was released from the Manila customhouse after the payment of duties by respondents Angela Alvaran and Elpidio Floresca. Subsequently, the Presidential Anti-Graft Committee (PAGCOM) intercepted the goods, alleging they were released without proper customs appraisal, causing government loss. Based on PAGCOM’s information, the Acting Collector of Customs initiated a seizure proceeding and issued a warrant of seizure and detention. PAGCOM agents also secured a search warrant from respondent Judge Andres Reyes to search the premises where the goods were stored.
The respondents (Alvaran, Floresca, and Africa) filed a petition for injunction (Civil Case No. 7883) in the Court of First Instance of Rizal, Branch VIII, presided by respondent Judge Guillermo Torres, seeking to restrain the customs authorities from enforcing the seizure warrant and to declare it null. Judge Torres issued a restraining order. Petitioners moved to lift it, asserting the Collector of Customs had exclusive jurisdiction. Judge Torres denied the motion, prompting this certiorari and prohibition petition.
ISSUE
Whether the Court of First Instance has jurisdiction to interfere with the seizure proceedings conducted by the Bureau of Customs.
RULING
No. The Supreme Court granted the petition, ruling that the Court of First Instance acted without jurisdiction. The Bureau of Customs has exclusive original jurisdiction over seizure and forfeiture cases under the Tariff and Customs Code. Once goods are seized under customs laws, the Collector of Customs retains custody and authority to conduct administrative proceedings. The regular courts cannot interfere through injunctive relief, as this would disrupt this exclusive jurisdiction.
The legal logic is that the issuance of a search warrant by a judge (Judge Reyes) for the dwelling where the goods were stored did not transfer custody or jurisdiction over the goods from the Bureau of Customs to the court. The search warrant merely authorized the entry and seizure; it did not divest the customs authorities of their administrative jurisdiction to determine forfeiture. The Court of First Instance, therefore, had no authority to entertain the injunction suit or to take custody of the goods, as doing so would encroach upon the exclusive domain of the Bureau of Customs and the appellate jurisdiction of the Court of Tax Appeals. All proceedings in Civil Case No. 7883 were declared null and void, and the lower court was prohibited from further interference.