Facts:

• The case involves the Bureau of Customs (petitioner) and Bush Boake Allen (Phils.), Inc. (respondent).
• Bush Boake Allen is a corporation registered with the Board of Investments, engaged in manufacturing, importing, and exporting chemical fragrances and flavors.
• On April 11, 1996, Filipino Way Industries, Inc. assigned Tax Credit Certificate (TCC) No. 004334 to Bush Boake as payment for chemicals supplied.
• The TCC was issued by the One Stop Shop Tax Credit and Duty Drawback Center of the Department of Finance on March 19, 1996.
• The TCC was later found to be fraudulently issued.
• The Bureau of Customs demanded payment from Bush Boake after the TCC was canceled on September 26, 2001.
• Bush Boake refused to pay, leading the Bureau of Customs to file a complaint for collection of the sum of money with damages before the Regional Trial Court (RTC) of Manila.
• The RTC ruled in favor of the Bureau of Customs, ordering Bush Boake to pay P2,462,650.00 with 6% interest.
• Bush Boake appealed to the Court of Appeals, which reversed the RTC's decision, finding Bush Boake to be a transferee in good faith and for value.
• The Bureau of Customs then filed this Petition for Review.

Issue:

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Ruling:

• The Supreme Court granted the Petition, ruling in favor of the Bureau of Customs.
• The Court held that the Regional Trial Court had jurisdiction over the case.
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Ratio:

• The Supreme Court first addressed the jurisdictional issue, affirming that the RTC had jurisdiction over the tax collection suit filed by the Bureau of Customs.
• The complaint for collection was filed in 2002, before the amendment of Republic Act No. 1125 by Republic Act No. 9282 in 2004.
• Under Republic Act No. 1125, the Court of Tax Appeals had exclusive appellate jurisdiction over decisions of the Collector of Internal Revenue, Commissioner of Customs, and Board of Assessment Appeals on disputed assessments of internal revenue taxes, customs duties, and real property taxes, but not tax collection cases.
• Therefore, the RTC had general jurisdiction over the collection case under Section 19(6) of Batas Pambansa Blg. 129, as amended.
• The Court referenced the case of Pilipinas Shell Petroleum Corporati...continue reading