Facts:

The case involves the Bureau of Customs (BOC) as the petitioner and several private respondents, including the Acting Secretary of Justice Agnes VST Devanadera, and various officers and directors of UNIOIL Petroleum Philippines, Inc. and OILINK International, Inc. The events leading to the case began on January 30, 2007, when Commissioner Napoleon L. Morales of the BOC issued Audit Notification Letter No. 0701246 to OILINK, indicating that a compliance audit would be conducted on its import transactions for the preceding three years. Following a pre-audit conference on March 2, 2007, OILINK submitted some documents but failed to provide all requested materials, citing employee resignations as a hindrance. The BOC Audit Team repeatedly requested additional documents, but OILINK continued to delay compliance. Consequently, on December 14, 2007, the BOC found OILINK liable for violations of Customs Administrative Order No. 4-2004, imposing a fine of approximately Php 2.76 billio...

Facts:

1. Parties Involved:

   • Petitioner: Bureau of Customs (BOC).
   • Respondents: The Honorable Agnes VST Devanadera, Acting Secretary of the Department of Justice (DOJ), and other private respondents, including UNIOIL Petroleum Philippines, Inc. and OILINK International, Inc., along with their officers and directors.

2. Background:

   • OILINK International, Inc. was subjected to a post-entry audit by the BOC for its import transactions over a three-year period.
   • OILINK failed to submit required documents despite repeated requests, leading to an administrative fine of P2,764,859,304.80 for violating Customs Administrative Order (CAO) No. 4-2004.
   • A Warrant of Seizure and Detention (WSD) was issued against OILINK’s shipments for failure to pay the fine.
   • UNIOIL, which had a Terminalling Agreement with OILINK, requested and was granted permission to withdraw its petroleum products from OILINK’s terminal, subject to conditions.

3. Allegations:

   • The BOC accused private respondents of illegally withdrawing petroleum products owned by OILINK without proper import documentation, resulting in a loss of P181,988,627 in customs value and P35,507,597 in duties and taxes.
   • The BOC filed a complaint-affidavit for violations of Sections 3601 and 3602 of the Tariff and Customs Code of the Philippines (TCCP).

4. DOJ Dismissal:

   • The DOJ dismissed the complaint for lack of probable cause, a decision upheld by the Acting Secretary of Justice.

5. Appeal to the CA:

   • The BOC filed a petition for certiorari with the Court of Appeals (CA), which dismissed it due to procedural defects, including the absence of a certification against forum shopping.

Issue:

1. Whether the CA erred in dismissing the petition for certiorari solely on the ground of procedural defects, specifically the lack of verification and certification against forum shopping.
2. Whether the CA committed a grave error in affirming its dismissal without addressing the substantive issue of probable cause.
3. Whether the Acting Secretary of Justice gravely abused her discretion in affirming the dismissal of the complaint for lack of probable cause.

Ruling:

1. On Procedural Defects:

   • The CA erred in dismissing the petition solely on procedural grounds. While procedural rules must generally be followed, the presence of special circumstances and public interest warranted relaxation of the rules.

2. On Substantive Issue (Probable Cause):

   • The Acting Secretary of Justice did not commit grave abuse of discretion in affirming the dismissal of the complaint for lack of probable cause. The BOC failed to prove that the withdrawn petroleum products were unlawfully imported or that private respondents committed fraudulent practices against customs revenue.

3. Jurisdiction Issue:

   • The petition for certiorari should have been filed with the Court of Tax Appeals (CTA) instead of the CA, as the CTA has exclusive jurisdiction over tax and customs matters.

Ratio:

• (Unlock)