Title
Commissioner of Customs vs. Manila Star Ferry, Inc.
Case
G.R. No. L-31776-78
Decision Date
Oct 21, 1993
A case involving the smuggling of foreign-made goods leads to the forfeiture of vessels, highlighting the importance of deterring smuggling activities and protecting government revenue.
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Case Digest (G.R. No. L-31776-78)

Facts:

  • The case "Commissioner of Customs v. Manila Star Ferry, Inc." revolves around the smuggling of foreign-made goods and the subsequent forfeiture of vessels.
  • Respondents include Manila Star Ferry, Inc., United Navigation & Transport Corporation, Ceaba Shipping Agency, Inc., and the Court of Tax Appeals.
  • On June 12, 1966, the S/S Argo, the Orestes, and the UN-L-106, along with two wooden bancas, were intercepted by a Philippine Navy patrol boat in the Explosives Anchorage Area of Manila Bay.
  • The crew of the S/S Argo was caught unloading foreign-made goods, such as 330 cases of cigarettes, assorted ladies' wear, clothing material, and plastic bags, onto the UN-L-106.
  • The UN-L-106 was being towed by the Orestes and escorted by the two bancas.
  • The goods were neither manifested nor declared for discharge in Manila, and no proper notice of arrival was given to local customs authorities.
  • Seizure and forfeiture proceedings were initiated against the vessels and their cargo, culminating in a decision by the Collector of Customs on December 27, 1966, to forfeit the vessels to the Philippine government.
  • This decision was affirmed by the Acting Commissioner of Customs on February 1, 1967.
  • Respondents appealed to the Court of Tax Appeals, which modified the decision on September 30, 1989, ordering the payment of fines instead of forfeiture.
  • The Commissioner of Customs contested this decision before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the S/S Argo cannot be forfeited under Section 2530(a) of the Tariff and Customs Code because it was apprehended in a port of entry.
  2. The Supreme Court ruled that the barge-lighter UN-L-106 and the ...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the clear and plain meaning of Section 2530(a) of the Tariff and Customs Code, which states that a vessel engaged in smuggling in a port of entry cannot be forfeited.
  • The Court emphasized that it is not within its jurisdiction to question the wisdom of the law or to add words not included by lawmakers.
  • The Court noted that the Revised Administrative Code of 1917, from which the Tariff and Customs Code is derived, contained nearly identical provisions, including the phrase "except a port of entry."
  • The Court also pointed out that Congress used the term "port of destination" in other subsections of Section 2530, indicating a clear distinction between the two terms.
  • Although the vessel S/S Argo cannot be forfeited, it is sub...continue reading

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