G.R. No. L-35385. January 31, 1983.
ALFREDO DE LA FUENTE, as Collector of Customs, Port of Sual, ROLANDO GEOTINA, as Commissioner of Customs, HILARIO RUIZ, as Flag Officer In Command, Philippine Navy, and GIL FERNANDEZ, as Commandant, Philippine Coast Guard, petitioners, vs. HON. JESUS DE VEYRA, in his capacity as Judge of the Court of First Instance of Manila, Branch XIV, LUCKY STAR SHIPPING COMPANY, and TENG BEE ENTERPRISES CO. (HK) LTD., respondents.

FACTS

On June 16, 1972, the Philippine Coast Guard apprehended the M/V Lucky Star I, a foreign vessel, off the coast of Zambales. It was caught unloading foreign-made cigarettes onto smaller watercrafts. The vessel’s captain could not present proper documents for the cargo. A warrant of seizure and detention was subsequently issued by the Collector of Customs against the vessel and the cigarettes for violations of the Tariff and Customs Code. A criminal information for smuggling was also filed in the Court of First Instance of Zambales.
Meanwhile, the vessel’s owner and the alleged cargo owner filed a complaint for injunction and recovery of personal property before the Court of First Instance of Manila, seeking the release of the vessel and goods. The respondent judge, while declining jurisdiction over the cigarettes, asserted jurisdiction over the vessel. He ruled that under Section 2530 of the Tariff and Customs Code, a vessel of more than thirty tons dead weight capacity could not be forfeited, only fined. He thus ordered the customs officials to inform the court of the maximum fine to set a bond for the vessel’s release.

ISSUE

Whether or not the Court of First Instance has jurisdiction to take cognizance of a complaint for the release of a vessel which is the subject of seizure and forfeiture proceedings before the Collector of Customs.

RULING

No. The Supreme Court granted the petition, setting aside the orders of the respondent court. The Collector of Customs, when conducting forfeiture proceedings, constitutes a tribunal vested with exclusive jurisdiction to hear and determine all matters relating to the seizure, including the legality thereof. The private respondents’ contention that the seizure occurred outside Philippine territorial waters—arguing the vessel was foreign-registered, manned by aliens, and seized 85 miles from the coast—is a defense that must be raised within the administrative forfeiture proceedings before the Bureau of Customs. It is not a proper subject for a separate civil action in the Court of First Instance. The law provides a clear appellate procedure from the Collector’s decision to the Commissioner of Customs and then to the Court of Tax Appeals. Allowing a parallel court action would undermine this specialized administrative process and lead to conflicting rulings. Consequently, the respondent judge was ordered to desist from further proceedings in the civil case. Jurisdiction over the vessel and the determination of the validity of its seizure reside exclusively with the customs authorities.