Case Digest (G.R. No. 94262)
Facts:
Feeder International Line, Pte., Ltd., by its agent, Feeder International (Phils.) Inc. v. Court of Appeals, Fourteenth Division, Court of Tax Appeals, and Commissioner of Customs, G.R. No. 94262, May 31, 1991, Supreme Court Second Division, Regalado, J., writing for the Court. The petition sought reversal of the Court of Appeals’ May 8, 1990 decision affirming the Court of Tax Appeals and the Customs authorities ordering forfeiture of the vessel M/T "ULU WAI" and its cargo.Feeder International Line, Pte., Ltd. (petitioner) owned or operated the foreign-registered vessel M/T "ULU WAI," which left Singapore on May 6, 1986 with 1,100 metric tons of gas oil and 1,000 metric tons of fuel oil consigned to Far East Synergy Corporation, Zamboanga. On May 14, 1986 the vessel anchored near Guiuanon Island, Guimaras (Iloilo) without notifying Iloilo customs; authorities learned of its presence from a civilian informer. A Customs team boarded on May 19, 1986 and found the vessel without the usual ship and shipping documents except for a Singapore port clearance.
Following investigation, a Warrant of Seizure and Detention was issued. Petitioner moved to dismiss and to quash the warrant; the District Collector denied that motion on December 12, 1986. The parties stipulated to a set of facts and documentary exhibits in the forfeiture proceeding (existence/identity of vessel and cargo; dates of arrival and boarding; the Port Clearance; sworn statements and a marine protest; a fixture note and survey report).
On March 17, 1987 the District Collector found the vessel and cargo violative of the Tariff and Customs Code (PD No. 1464) and ordered forfeiture. The Commissioner of Customs affirmed that decision in toto on May 13, 1987. Petitioner filed a petition for review with the Court of Tax Appeals on June 25, 1987; the C.T.A. on December 14, 1988 affirmed the forfeiture. Petitioner sought review in this Court on January 19, 1990; the Court on March 21, 1990 referred the case to the Court of Appeals pursuant to Development Bank of the Philippines v. Court of Appeals. The Court of Appeals rendered judgment on May 8, 1990 affirming the C.T.A.; its denial of petitioner’s motion for reconsideration was dated July 4, 1990. Petitioner then filed the present petition to this Court.
In its Supreme Court petition, petitioner argued (1) that the courts below relied on circumstantial evidence improperly invoking Section 5 (now Section 4), Rule 133,...(Subscriber-Only)
Issues:
- Is a corporate petitioner entitled to invoke the criminal-law presumption of innocence in administrative forfeiture proceedings?
- Was there sufficient evidence to support the finding of illegal importation or an attempt to import, justifying forfeiture of the vessel and cargo under the Tariff and Customs Code?
- Does the circumstantial-evidence standard of Section 5 (now Section 4), Rule 133, Rules of Court—requiring proof beyond reasonable doubt—apply to forfeiture proceedings under the Tariff and Customs Code?
- Were the sworn statements of the vessel’s master and agent, taken without counsel, inadmi...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)