G.R. No. L-24003 November 28, 1975
Hadji Mohamad Daud, petitioner-appellee, vs. The Collector of Customs of the Port of Zamboanga City, respondent-appellant.

FACTS

The motor launch M/L “MISS HURAIRA,” owned by Hadji Mohamad Daud, was intercepted carrying untaxed blue seal cigarettes. The Collector of Customs for Zamboanga City instituted seizure proceedings and declared the vessel forfeited in favor of the government. Daud requested redemption of the vessel under Section 2307 of the Tariff and Customs Code, which the Collector denied, citing a Presidential directive against redeeming vessels used in smuggling and potential prejudice to a related criminal case. Daud did not appeal this denial administratively. Instead, he filed a petition for mandamus directly with the Court of First Instance of Zamboanga City to compel the redemption. The lower court granted the petition, ordering the vessel’s release upon payment of its appraised value and the posting of a bond.

ISSUE

Whether a regular Court of First Instance possesses jurisdiction to order, via mandamus, the redemption of a vessel forfeited by the Collector of Customs.

RULING

No. The Court of First Instance lacked jurisdiction. The Supreme Court reversed the lower court’s order and dismissed the mandamus suit. The legal logic is anchored on the doctrine of exclusive appellate jurisdiction over customs forfeiture proceedings. Republic Act No. 1125 grants the Court of Tax Appeals exclusive appellate jurisdiction to review decisions of the Commissioner of Customs on matters like seizure and forfeiture. The Collector of Customs, when sitting in forfeiture proceedings, acts as a tribunal with exclusive original jurisdiction. Judicial recourse for an aggrieved party must follow the prescribed administrative hierarchy: an appeal from the Collector’s decision to the Commissioner of Customs, and then to the Court of Tax Appeals. Regular courts cannot interfere through writs of certiorari, prohibition, or mandamus, as these are, in substance, attempts to review customs rulings. By filing mandamus directly with the Court of First Instance instead of exhausting this administrative and specialized appellate remedy, Daud improperly invoked the regular court’s jurisdiction.