Facts:

The case involves Bienvenido Capulong as the petitioner and the Acting Commissioner of Customs as the respondent. The events leading to this case began on October 2, 1954, when Capulong imported 63 packages of assorted merchandise from Hong Kong into the Philippines. This importation was declared under Entry No. 78008, series of 1954, and was supported by a bill of lading, a commercial invoice, and an official receipt that confirmed the payment of customs duties and sales taxes. However, the importation lacked the necessary import license and release certificate from the Central Bank, leading to its seizure by the Collector of Customs for the Port of Manila under Seizure Identification No. 2025. The seizure was based on alleged violations of Central Bank Circulars Nos. 44 and 45, in conjunction with Section 1363(f) of the Revised Administrative Code.

During the seizure proceedings, the shipment was released to Capulong under Surety Bond No. 093, amounting to P12,543.00, po...

Facts:

1. Importation Details: On October 2, 1954, petitioner Bienvenido Capulong imported 63 packages of assorted merchandise from Hongkong into the Philippines. The shipment was declared under Entry No. 78008, series of 1954, and was covered by a bill of lading, commercial invoice, and official receipt evidencing payment of customs duties and sales taxes.
2. Seizure of Goods: The importation was seized by the Collector of Customs for the Port of Manila under Seizure Identification No. 2025 because it was not covered by an import license or release certificate from the Central Bank, allegedly violating Central Bank Circulars Nos. 44 and 45 in relation to Section 1363(f) of the Revised Administrative Code.
3. Release Under Bond: During the pendency of the seizure proceeding, the shipment was released to petitioner under Surety Bond No. 093 in the sum of P12,543.00, posted by Pioneer Insurance & Surety Corporation. The value of the shipment was $4,433.00, and the importation was effected through the no-dollar remittance system.
4. Commissioner's Decision: On March 10, 1960, the respondent Commissioner of Customs declared the forfeiture of the articles in favor of the government and ordered petitioner and the surety to jointly and severally pay P12,530.00 to the Bureau of Customs.
5. Appeal to Court of Tax Appeals: Petitioner appealed the decision to the Court of Tax Appeals. Pending the appeal, the Monetary Board of the Central Bank issued Circular No. 133 on January 21, 1962. On February 24, 1964, the Court of Tax Appeals affirmed the Commissioner's decision.

Issue:

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Ruling:

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Ratio:

1. Forfeiture Under Section 1363(f): The Court held that while Central Bank Circulars Nos. 44 and 45 do not expressly provide for forfeiture, the forfeiture of goods imported in violation thereof is justified under Section 1363(f) of the Revised Administrative Code (now Section 2530(f) of the Tariff and Customs Code). This section authorizes the forfeiture of "any merchandise of prohibited importation or exportation, the importation or exportation of which is effected or attempted contrary to law." Although the goods may not be classified as "prohibited," they fall under the category of merchandise imported "contrary to law" because regulations issued pursuant to customs laws form part thereof.
2. No Repeal of Circulars Nos. 44 and 45: The Court ruled that Central Bank Circular No. 133 did not repeal Circulars Nos. 44 and 45. Instead, Circular No. 133 re-enacted them by incorporating all existing regulations not inconsistent with it. Both sets of circulars share a common purpose: to require a release certificate from the Central Bank before any importation into the Philippines. This requirement aims to monitor the volume of imports and enable the Central Bank to address the country's financial crisis.