Title
Agriex Co., Ltd. vs. Villanueva
Case
G.R. No. 158150
Decision Date
Sep 10, 2014
Agriex's rice shipment to Subic Free Port was seized by Customs; Supreme Court upheld Customs' jurisdiction, ruling Agriex should have appealed to CTA.
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Case Digest (G.R. No. 158150)

Facts:

  • Contract and Shipment: Agriex Co., Ltd., a foreign corporation based in Bangkok, Thailand, entered into contracts for the sale of Thai white rice. On July 27, 2001, it chartered the vessel MV Hung Yen to transport 200,000 bags of rice to the Subic Free Port for transshipment to Fiji, Indonesia, and Cebu City.
  • Delay and Customs Involvement: The MV Hung Yen arrived at Subic Free Port on August 20, 2001, but was only allowed to berth on September 11, 2001. The Bureau of Customs issued a Warrant of Seizure and Detention (WSD) on September 12, 2001, against 20,000 bags of rice consigned to R&C Agro Trade, even though no rice had been unloaded.
  • Amended Warrants and Auction: On September 27, 2001, amended WSDs were issued to include the remaining 180,000 bags and the MV Hung Yen. On October 18, 2001, a Notice of Sale was issued for the auction of the 200,000 bags of rice.
  • Legal Proceedings: Agriex filed an Urgent Motion to Quash the WSDs, but the Collector of Customs denied the motion and ordered forfeiture of the rice shipments on November 14, 2001. Agriex appealed to the Commissioner of Customs, who modified the order, releasing the 20,000 bags to R&C Agro Trade upon payment but affirming the forfeiture of the 180,000 bags.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of the Bureau of Customs: The Subic Freeport is a separate customs territory, but the Bureau of Customs retains exclusive jurisdiction over seizure and forfeiture cases involving violations of customs laws, even within the Freeport.
  2. Proper Remedy: Agriex’s recourse was to appeal the Commissioner’s February 4, 2002 Consolidated Order to the CTA. Since it failed to do so, the order became final and executory.
  3. Notice of Sale: The issuance of the Notice of Sale was incidental to the seizure proceedings, which were within the Bureau of Customs’ jurisdiction.


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