G.R. No. 70648 - Commissioner of Customs vs. Court of Tax Appeals

Campos Rueda Corporation imported two types of merchandise from the United States: tungsol flashers and sealed beams.
For the tungsol flashers:

The first shipment, worth US$10,812.20, arrived in Manila on November 1, 1973, with an Import Entry filed quoting a unit price of US$0.66 per piece.
The second shipment, valued at US$18,220.10, arrived on February 12, 1974, also with an Import Entry that declared the same unit price.

A shipment worth US$18,964.54 arrived on March 31, 1974 with an Import Entry filed, quoting an invoice price of US$0.908 per piece.

The Bureau of Customs re-appraised the declared values using an "Alert Notice" purportedly issued by Finance Attaches abroad:

As a consequence of the re-appraisal, Campos Rueda Corporation remitted additional taxes and duties:

Campos Rueda Corporation filed Manila Protests Nos. 9274, 9275 (for flashers), and 9287 (for sealed beams) seeking a refund of the overpaid customs duties.
The Collector of Customs of Manila denied the protests, leading the respondent company to seek recourse with the Commissioner of Customs.
The Commissioner of Customs affirmed the re-appraisal based on the reliance on the "Alert Notices" and its duty to inform the Department of Finance of current commodity prices.
The case was elevated to the Court of Tax Appeals, which rendered a judgment on March 19, 1985, modifying the earlier decision by ordering that only the amount of overpaid customs duties be refunded.

Section 201 of the Tariff and Customs Code of the Philippines (RA No. 1937, as amended) prescribes:

The dutiable value of an imported article shall be based on the home consumption value or price declared in the consular, commercial, trade, or sales invoice.
In cases of reasonable doubt regarding the declared price, the value should be ascertained from reports of Revenue or Commercial Attaches and other available data, with proper publication of such values.

The Commissioner’s re-appraisal, however, relied solely on "Alert Notices" without disclosing the underlying data or fulfilling the publication requirement set by law.

The records do not indicate that the data or the "Alert Notices" were ever presented to or disclosed before the affected parties or the Court.
The absence of disclosure raised serious due process concerns, given that administrative findings must be supported by substantial evidence.

Whether or not the re-appraisal made by the Commissioner of Customs was in strict conformity with Section 201 of the Tariff and Customs Code, particularly regarding:

The basis for determining the dutiable value of imported merchandise.
The use of "Alert Notices" from Finance Attaches abroad as the sole basis for re-appraisal without corresponding disclosure or adherence to the statutory publication requirements.

Whether the administrative action, which resulted in the overpayment and subsequent refund claim by Campos Rueda Corporation, conformed to the due process requirements essential in administrative proceedings.