Facts:

The case involves a petition for review on certiorari filed by The Hon. Cornelio Balmaceda, in his capacity as Secretary of Commerce and Industry and Chairman of the Producers Incentive Board, against Corominas & Company, Inc. The events leading to the case began on January 29, 1959, when Corominas was issued Barter Permit No. 1604-Spl. by then Secretary of Commerce and Industry, Pedro C. Hernaez. This permit allowed Corominas to export 20,000 metric tons of Rhodesian corn valued at $1,575,100.00 to Japan and to import commodities of equivalent value under a straight barter system as stipulated in Republic Act No. 1410. The permit included a condition that non-essential imports should not exceed 10% of the total imports.

Corominas successfully exported the corn, but the Japanese buyer faced restrictions from the Japanese government regarding dollar remittances. Consequently, the buyer was allowed to settle the remaining balance of $485,030.33 in commodities. Corominas s...

Facts:

1. Legislative Background:

   • Republic Act No. 1410 was enacted on September 10, 1959, to regulate "no-dollar" imports, allowing imports only under specific conditions, including straight barter transactions authorized by the Secretary of Commerce and Industry.
   • The Department of Commerce and Industry was tasked with implementing the Act and issued Consolidated Rules and Regulations, which included a provision limiting non-essential imports to 10% of total imports.

2. Corominas & Company, Inc.:

   • Corominas & Company, Inc. (Corominas) is a Philippine corporation engaged in export and import business.
   • On January 29, 1959, Corominas was issued Barter Permit No. 1604-Spl., allowing it to export Rhodesian corn to Japan and import goods of equivalent value under the straight barter system.

3. Importation Dispute:

   • Corominas exported 20,000 metric tons of Rhodesian corn to Japan, but the Japanese buyer faced difficulties remitting U.S. dollars due to government restrictions.
   • The buyer instead offered to pay the balance of $485,030.33 in commodities, which Corominas sought to import under the barter permit.
   • The Producers Incentives Board granted the request but imposed conditions, including adherence to the 10% limit on non-essential imports.

4. Exceeding the 10% Limit:

   • Corominas submitted firm offers for importation, but the Producers Incentives Board later informed Corominas that its non-essential imports exceeded the 10% limit.
   • Corominas sought reconsideration, but the Board denied the request, leading to a legal dispute.

5. Legal Proceedings:

   • Corominas filed a complaint in the Court of First Instance of Manila, seeking the issuance of release certificates for its imported goods.
   • The trial court ruled in favor of Corominas, and the Court of Appeals affirmed the decision.
   • The case was elevated to the Supreme Court for review.

Issue:

1. Whether the letters (Exhibits D, D-1 to D-10) issued by the Producers Incentives Board constituted authority for Corominas to import goods, or were they merely confirmations of classifications and price quotations?
2. Whether Corominas exceeded the 10% limit on non-essential imports under the Consolidated Rules and Regulations.
3. Whether the Consolidated Rules and Regulations, as administrative rules, have the force and effect of law and can be enforced against Corominas.
4. Whether the excess importation of non-essential goods by Corominas is subject to seizure and confiscation under Section 3 of Republic Act No. 1410.

Ruling:

1. On the Nature of the Letters:

   • The Supreme Court held that the letters (Exhibits D, D-1 to D-10) were merely confirmations of the classifications and price quotations of the goods proposed for importation, not authorizations to import. The authority to import was already granted through the Barter Permit and subsequent authorization by Acting Undersecretary Mariano G. Pineda.

2. On the 10% Limit:

   • The Court ruled that Corominas had indeed exceeded the 10% limit on non-essential imports. The 10% limit was based on the actual value of imports ($485,030.33), not the total permit value ($1,575,100.00). Corominas imported $103,233.44 worth of non-essential goods, exceeding the allowable $48,503.33 by $54,730.44.

3. On the Force of the Consolidated Rules and Regulations:

   • The Court affirmed that the Consolidated Rules and Regulations, promulgated under Republic Act No. 1410, have the force and effect of law and cannot be waived or renounced by the Secretary of Commerce and Industry.

4. On Seizure and Confiscation:

   • The Court declared that the excess importation of non-essential goods ($54,730.44) was illegal and subject to seizure and confiscation under Section 3 of Republic Act No. 1410. The bond posted by Corominas could be used to satisfy the forfeited amount.

Ratio:

1. Administrative Rules as Law:

   • Administrative rules and regulations, when promulgated under statutory authority, have the force and effect of law. The Consolidated Rules and Regulations, issued under Republic Act No. 1410, are binding and enforceable.

2. Limitation on Non-Essential Imports:

   • The 10% limit on non-essential imports applies to the actual value of imports, not the total permit value. This ensures compliance with the policy objectives of Republic Act No. 1410.

3. No Estoppel Against the Government:

   • The government is not estopped by the mistakes or errors of its agents. Even if the Producers Incentives Board initially confirmed the classifications and price quotations, it could later enforce the 10% limit without being estopped.

4. Confiscation of Excess Imports:

   • Excess importation of non-essential goods violates Republic Act No. 1410 and is subject to seizure and confiscation. The bond posted by the importer can be used to satisfy the forfeited amount.

Conclusion:

The Supreme Court reversed the decision of the Court of Appeals, ruling that Corominas exceeded the 10% limit on non-essential imports and that the excess importation was illegal and subject to confiscation. The bond posted by Corominas could be used to satisfy the forfeited amount.