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:
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Ruling:
- 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.
- 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
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, leading to the forfeiture of vessels. The respondents in this case are Manila Star Ferry, Inc., United Navigation & Transport Corporation, Ceaba Shipping Agency, Inc., and the Court of Tax Appeals. The incident took place on June 12, 1966, when 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, including 330 cases of cigarettes, assorted ladies' wear, clothing material, and plastic bags, onto the UN-L-106, which was being towed by the Orestes and escorted by the two bancas. These goods were not manifested or 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, resulting in a decision by the Collector of Customs on December 27, 1966, to forfeit the vessels in favor of the Philippine government. This decision was affirmed by the Acting Commissioner of Customs on February 1, 1967. The respondents then 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 challenge...