Case Digest (G.R. No. 246343)
Facts:
The Bureau of Customs and the Commissioner of Customs v. Jade Bros. Farm and Livestock, Inc., G.R. No. 246343, November 18, 2021, the Supreme Court First Division, Lopez, J., writing for the Court.Petitioners are the Bureau of Customs (BOC) and the Commissioner of Customs; respondent is Jade Bros. Farm and Livestock, Inc. (JBFLI), a domestic trader of agricultural products that entered into rice importations in 2013. Upon arrival at the Manila International Container Port (MICP), the District Collector of Customs refused to release several rice shipments on the ground that JBFLI lacked a National Food Authority (NFA) import permit.
JBFLI filed a petition for declaratory relief and injunctive relief in the Regional Trial Court (RTC), Manila (Civil Case No. 14-131418) on February 13, 2014, challenging the legal basis for the import-permit requirement and seeking, among other things, a TRO/preliminary injunction restraining respondents from requiring import permits or seizing its rice shipments. While that RTC action was pending, JBFLI communicated with the MICP District Collector (letters of June 2 and July 11, 2014) asking either for release of the shipments, release under cash bond or issuance of Warrants of Seizure and Detention (WSDs). The District Collector issued four WSDs dated July 21, 2014 (SIC Nos. 356–359-2014), and JBFLI filed a Consolidated Motion for Release Under Cash Bond before the District Collector.
Despite JBFLI’s motion, the District Collector posted notices of public auction (initially for August, later rescheduled to September and again to October). On September 3, 2014, in view of the impending sale, JBFLI filed a Petition for Review with Application for TRO/Writ of Preliminary Injunction and Release Under Bond with the Court of Tax Appeals (CTA), docketed as CTA Case No. 8886 (Third Division). The CTA Third Division issued a 20‑day TRO on September 11, 2014 enjoining the September 11 auction, but the TRO expired and the District Collector nevertheless posted an October 7, 2014 notice; the auction was conducted on October 17, 2014 and the rice shipments were sold.
On September 21, 2016 the CTA Third Division ruled that it had jurisdiction, that JBFLI had not engaged in forum‑shopping, and that JBFLI’s imports were legal; it ordered release to JBFLI of the auction proceeds held in trust, less applicable charges. The Third Division affirmed that resolution on November 25, 2016. The BOC and Commissioner sought en banc review; in CTA EB Case No. 1566 the CTA en banc issued a July 4, 2018 Decision concluding the Third Division lacked jurisdiction and that JBFLI engaged in forum‑shopping, but because the en banc did not obtain the affirmative votes needed to reverse the Division rulings, those Third Division resolutions were affirmed. The en banc’s July 4, 2018 D...(Pro-only)
Issues:
- Could the CTA Third Division entertain JBFLI’s petition for review under the circumstances (i.e., was the District Collector’s action appealable and were administrative remedies exhausted)?
- Did JBFLI engage in forum‑shopping by filing the petition for review before the CTA while Civil Case No. 14‑131418 bef...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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