G.R. No. and Date: G.R. Nos. L-9638 and 9789, March 27, 1915

FACTS:
On October 7, 1913, petitioner Chun Toy attempted to enter 50 cases of hams imported from Hongkong at the Manila customhouse. The Insular Collector of Customs refused entry because the petitioner failed to submit a certificate of official ante-mortem and post-mortem inspections of the animals from which the hams were derived, as required by Customs Administrative Circular No. 628. The Collector issued this circular pursuant to his rule-making authority under the Philippine Tariff Act of 1909. Chun Toy filed a petition for a writ of mandamus in the Court of First Instance of Manila to compel the Collector to accept his declaration of entry and deliver the goods, subject to an examination to determine if they were dangerous to health. The lower court granted the writ, prompting the Collector to appeal.

ISSUE:
Whether the Insular Collector of Customs had the authority to promulgate and enforce Customs Administrative Circular No. 628, which requires a certificate of ante-mortem and post-mortem inspection for imported meats as a condition for entry.

RULING:
The Supreme Court reversed the judgment of the lower court and affirmed the ruling of the Insular Collector of Customs.

The Court held that the Collector’s action was a valid exercise of his administrative authority under the Philippine Tariff Act of 1909 (Act of Congress of August 5, 1909). Section 3 of this Act prohibits the importation of any article violating the U.S. Pure Food and Drugs Act of 1906. Section 25 authorizes the Insular Collector to make necessary rules and regulations to enforce the Act.

The Court rejected the petitioner’s arguments:
1. The Collector was not enforcing the Pure Food Law per se, but the Tariff Law which incorporates its prohibitions. The administrative determination of admissibility is distinct from a judicial prosecution under the Pure Food Law, and the rules on burden of proof in courts do not strictly apply.
2. The requirement of an inspection certificate is a reasonable and necessary regulation to effectively determine if imported meat is diseased or deleterious to health, thereby fulfilling the duty to exclude prohibited articles. It is not an improper attempt to enforce the U.S. Meat Inspection Law.
3. The constitutional doctrine regarding the immunity of original packages from state regulation in interstate commerce is inapplicable to the Philippines, as it is not a state or territory of the United States.

Therefore, Customs Administrative Circular No. 628 was a valid regulation, and the Collector properly refused entry of the goods for non-compliance. A similar judgment was entered in the consolidated case ( G.R. No. 9789 ).