Facts:
Commissioner of Customs filed consolidated petitions for certiorari and prohibition challenging a series of orders and decisions arising from the entry into Philippine waters of the vessel
M/V "Star Ace" on January 7, 1989, then at San Fernando, La Union, with an appraised value of about P200,000,000, after seizure proceedings under S.I. Nos. 02-89 and 03-89 and issuance of two
warrants of seizure and detention;
Cesar S. Urbino, Sr. asserted a preferred maritime lien under a Salvage Agreement dated June 8, 1989 and pursued several remedies in both administrative and judicial fora. Urbino filed a certiorari, mandamus and damages case in the RTC of San Fernando (Civil Case No. 89-4267) on July 26, 1989, which the RTC dismissed for lack of jurisdiction on January 31, 1991 and which thereafter reached the Court of Appeals as CA-G.R. CV No. 32746. Urbino also filed an in rem action in the
Regional Trial Court of Manila (Civil Case No. 89-51451) on January 9, 1990 to enforce his maritime lien; the Office of the Solicitor General secured partial dismissal on July 2, 1990 as to the Commissioner and District Collector, but the RTC of Manila proceeded against other parties and on February 18, 1991 rendered judgment for Urbino and on March 13, 1991 issued a writ of execution. A special sheriff levied and auctioned the vessel and cargo to Urbino for P120,000,000, but Judge Arsenio M. Gonong issued cease-and-desist and recall orders; Urbino obtained a TRO and later preliminary injunction from the
Court of Appeals restraining enforcement of the RTC orders. Urbino filed a separate petition in the
Regional Trial Court of Kalookan (Civil Case No. C-234) on May 8, 1991, which court on May 28, 1991 issued a writ of preliminary injunction against the Philippine Ports Authority and the Bureau of Customs to permit relocation of the vessel; Executive Judge Bernardo P. Pardo of the RTC of Manila nullified the sheriff’s report and proceedings on June 26, 1992, prompting another CA petition and TRO on August 6, 1992. Meanwhile, forfeiture proceedings before the
Court of Tax Appeals (CTA Cases Nos. 4492, 4494, 4500) were pending; Urbino’s CTA case was dismissed for lack of capacity but he was allowed to intervene in CTA No. 4500, and the CTA on October 5, 1992 authorized inventory and guarded custody. Urbino sought further relief from the CA (CA-G.R. SP Nos. 24669, 28387, 29317) and the CA consolidated the petitions and on July 19, 1993 granted them, nullifying the RTC recall and nullification orders and the CTA order and making the injunctions permanent in favor of Urbino. The
Commissioner of Customs then petitioned the Supreme Court, which rendered judgment on January 31, 2006 annulling and setting aside various RTC and CA rulings and ordering the CTA to proceed with its forfeiture cases.
Issues:
Did the Court of Appeals err in denying the Commissioner of Customs’ Motion to Suspend Proceedings in CA-G.R. CV No. 32746 and should the CA be prohibited from further acting in that case? Did the Regional Trial Court of Kalookan commit reversible error in issuing a writ of preliminary injunction against the Philippine Ports Authority and the Bureau of Customs in Special Civil Case No. C-234? Did the Regional Trial Court of Manila acquire jurisdiction over the
M/V "Star Ace" such that its February 18, 1991 decision and the writ of execution thereon could validly bind the vessel and its cargo, and did the Court of Appeals err in enjoining the
Court of Tax Appeals and setting aside CTA proceedings?
Ruling:
Ratio:
Doctrine: