Case Digest (G.R. No. 16172)
Facts:
The case involves J. J. J. Addenbrooke, the plaintiff and appellee, who is a resident of Cebu City and the owner of a motor yacht named Cecilia, which weighs approximately 22 tons gross. The yacht is exclusively used for pleasure and recreational activities and is not engaged in transporting passengers or freight for profit. The vessel is powered by an oil-burning internal combustion engine rather than steam. Prior to this legal action, Joaquin Natividad, who served as the Collector of Customs for Cebu and is the defendant and appellant in this case, mandated that Addenbrooke must designate a licensed patron for the yacht, to comply with subsection (e) of section 1203 of the Administrative Code of the Philippines.
Disputing this requirement, Addenbrooke filed a complaint in the Court of First Instance of Cebu, seeking a perpetual injunction to prevent the collector from enforcing this mandate. The court initially ruled in favor of Addenbrooke. Natividad subsequently appealed th
Case Digest (G.R. No. 16172)
Facts:
- Plaintiff: J. J. J. Addenbrooke, a resident of Cebu and owner of the motor yacht Cecilia.
- Defendant: Joaquin Natividad, Collector of Customs for Cebu.
Background of the Parties
- The Cecilia is a motor yacht of approximately 22 tons gross.
- It is powered by an internal combustion engine (oil burning) rather than by steam.
- The yacht is operated exclusively for pleasure and recreation, not for carrying passengers or freight for profit.
Description of the Vessel
- The defendant required the plaintiff to have a licensed patron (master) in charge of the vessel as mandated by subsection (e) of section 1203 of the Administrative Code, which stipulates the required complement of officers.
- The law, as written, applies to “every vessel registered in the Philippine Islands” and classifies registered vessels as either steam vessels or sailing vessels.
- There is no explicit category for motor boats, leading to the question of whether a motor yacht like the Cecilia should be considered a steam vessel for regulatory purposes.
Regulatory Basis and Controversy
- The plaintiff filed an action in the Court of First Instance of Cebu for a perpetual injunction to prevent the enforcement of the licensing requirement.
- A favorable judgment was rendered in favor of the plaintiff at the trial level.
- The defendant subsequently appealed the decision.
Legal Proceedings
- Section 1419 of the Administrative Code defines “vessel” to include all manners of artificial contrivances used or capable of being used for water transportation.
- Section 1167 mandates the registration of vessels of more than 3 tons gross in Philippine waters.
- Section 1203, from which the requirement in question is derived, only recognizes the categories of steam vessels and sailing vessels, leaving motor boats as a casus omissus.
- Customs Marine Circular No. 53 (October 22, 1912) defined “steam vessel” to include any vessel propelled by machinery, an interpretation that was widely accepted, including in American jurisprudence (e.g., The Nimrod case).
Statutory and Regulatory References
Issue:
- Whether a motor yacht propelled by an internal combustion engine should be classified as a “steam vessel” under the language of section 1203 of the Administrative Code.
Classification of the Vessel
- Whether the statutory requirement to have one patron in the minor coastwise trade applies to a vessel used exclusively for pleasure and recreation.
- The interpretation of the phrase "in the minor coastwise trade" as a classification of the officer rather than an indication of the vessel's commercial purpose.
Applicability of Officer Complement Requirements
- How the historically established Customs Marine Regulations impact the modern interpretation of the law.
- Whether the omission of a separate category for motor boats indicates legislative intent to subsume them under the category of steam vessels.
Legislative Intent and Regulatory Consistency
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)