G.R. No. 166901 - Asian Terminals, Inc. vs. Bautista-Ricafort

Several duly licensed importers (Noel Tabuelog, Ernesto de Jesus, Norma Pondevida, Renato Claros, Ernesto M. Chua, Cecilia Saulog, Jenelita Naparate, Rodolfo Mago, and Amalia Edamura) imported 72 secondhand right-hand drive buses from Japan during April and May 1998.
Section 1 of Republic Act (RA) No. 8506, effective February 22, 1998, prohibits the importation, registration, use, and operation of vehicles with the steering wheel on the right-hand side on any highway, street, or road.
The legal disputes centered around whether the importation was prohibited, particularly when conversion kits were allegedly incorporated in the importation process.

Upon the arrival of the shipment at South Harbor, Port of Manila, the District Collector of Customs impounded the vehicles and stored them at Asian Terminals, Inc. (ATI), a customs-bonded warehouse.
In accordance with Section 2607 of the Tariff and Customs Code, the District Collector issued Warrants of Distraint against the shipment and scheduled a public auction on September 10, 1998.
A subsequent Opinion No. 127 (dated October 28, 1998) by the Secretary of Justice stated that, unless loaded and imported after February 22, 1998, right-hand drive vehicles are not covered by RA No. 8506.

On November 11, 1998, the importers (through attorney Samuel N. Rosete, acting in his personal capacity and as attorney-in-fact) filed a complaint in the RTC of Parañaque City seeking replevin and damages.
The complaint argued that, based on the legal opinions of Customs Legal Service and the Legal Affairs Office of the Department of Finance, the importation was not prohibited provided conversion kits were included.
The prayer of the complaint was dual-pronged: initially requesting a writ of replevin to secure the vehicles and subsequently claiming monetary relief for damages and related expenses.

The RTC granted the application for the writ of replevin on a bond of ₱12,000,000.00.
Enforcement difficulties arose when Customs Police, led by Chief George Jeroes, obstructed the Sheriff’s attempt to seize the vehicles by invoking the jurisdiction of the District Collector of Customs.
A subsequent RTC order (November 23, 1998) directed the PNP Director to assist in enforcing the writ, leading to the eventual seizure and issuance of a custody receipt.

The District Collector agreed to transfer custody of the vehicles to the RTC provided that the importers paid due taxes, dues, and charges amounting to ₱7,528,635.00; the importers complied with this condition.
Shortly thereafter, the Office of the Solicitor General (OSG) filed an omnibus motion seeking reconsideration of the writ, arguing that the RTC lacked jurisdiction because the Bureau of Customs had exclusive control over the impounded vehicles.
ATI, the warehouse operator, intervened by filing a third-party claim asserting a lien over the vehicles for unpaid storage, arrastre, and wharfage charges, which further complicated the proceedings.

Plaintiffs moved to dismiss the complaint against Customs and finance officials on the basis that payment of the required charges legalized their importation.
The OSG challenged this motion, arguing that the legality of the importation remained in question under RA No. 8506 regardless of the payment of charges.

ATI argued for its lien by insisting that plaintiffs post a bond to guarantee the payment of its claims.
Plaintiffs contended that ATI failed to establish a factual or contractual basis for its lien, and that no valid contract existed regarding wharfage and arrastre services.

On April 27, 1999, the RTC dismissed the main complaint on jurisdictional grounds, noting that the Court of Tax Appeals holds exclusive appellate jurisdiction over seizure and forfeiture matters.
Additional motions for reconsideration and clarification were filed by both the OSG and ATI. On September 23, 1999, the RTC dismissed ATI’s complaint-in-intervention, ordering the return of the buses.
ATI’s subsequent motion for reconsideration was denied on July 31, 2000, with the Court reiterating that the buses were under custodia legis by virtue of the writ of replevin, despite jurisdictional defects.

ATI filed a Petition for Certiorari under Rule 65 before the Court of Appeals challenging the RTC’s dismissal of the main complaint, the denial of its motion for reconsideration, and the dismissal of its complaint-in-intervention.
The CA, on November 30, 2004, dismissed the petition for lack of merit, ruling that the RTC lacked jurisdiction over seizure and forfeiture cases as under the Customs and Tariff Code (TCC), such matters are reserved for the Collector of Customs and the Court of Tax Appeals.
The appellate decision rested on the exclusive jurisdiction of Customs authorities over import and export matters and on established precedents limiting the scope of intervention to ancillary issues that do not create an independent action.

Whether the RTC had jurisdiction to entertain the complaint for replevin and related motions despite Customs having exclusive jurisdiction over seized vehicles under the TCC.
Whether the transfer of vehicles’ custody to the RTC upon payment of taxes and charges conferred jurisdiction upon the RTC over the subject matter.

Whether the RTC’s issuance and enforcement of the writ of replevin were valid given the objections raised by Customs officials regarding jurisdiction.
Whether the subsequent actions by Customs Police and the District Collector impacted the legality of the writ’s implementation.

Whether ATI’s third-party claim (transformed into a complaint-in-intervention) can survive the dismissal of the main complaint.
Whether intervention is permissible when the principal action is dismissed, particularly when the claim involves the recovery of dues for storage and related charges.

Whether the provisions of RA No. 8506 and the TCC exclusively allocate jurisdiction to Customs authorities and the Court of Tax Appeals, thereby precluding RTC involvement.
How precedents such as Jao v. Court of Appeals and the Metropolitan Bank case impact the question of intervention and the rights of intervenors.