Case Digest (G.R. No. 16224)
Facts:
Intra-Strata Assurance Corporation and Philippine Home Assurance Corporation v. Republic of the Philippines, G.R. No. 156571, July 09, 2008, Supreme Court Second Division, Brion, J., writing for the Court. Petitioners are Intra-Strata Assurance Corporation and Philippine Home Assurance Corporation (collectively, the sureties); respondent is the Republic of the Philippines, represented by the Bureau of Customs (the government/creditor). The case arose from a collection suit filed by the Bureau of Customs to recover customs duties, internal revenue taxes, and other charges on importations effected by Grand Textile Manufacturing Corporation (the importer/principal).In 1974 Grand Textile imported various articles which were placed in Customs Bonded Warehouse No. 462. The Bureau of Customs computed unpaid duties and charges totaling approximately P2,363,147.00. To permit warehousing without immediate payment, petitioners issued general warehousing bonds required by Section 1904 of the Tariff and Customs Code; the bonds conditioned the goods’ withdrawal upon payment of the legal duties, taxes and charges or otherwise kept the bond in force until the obligations were discharged.
Despite nonpayment, Grand Textile withdrew the goods for domestic consumption. The Bureau of Customs demanded payment from Grand Textile and from petitioners as sureties; none paid. On January 14, 1983 the government filed a collection action in the Regional Trial Court (RTC), Branch 20, Manila (Civil Case No. 83-15071). After trial, the RTC rendered judgment on January 4, 1995, finding Grand Textile and the petitioners jointly and severally liable for the amounts due, ordering forfeiture of the bonds and awarding costs and interest as specified in the dispositive portion.
The Court of Appeals affirmed the RTC in a decision dated November 26, 2002. Petitioners then filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court, challenging (a) that withdrawal of the goods without notice released them from bond liability and (b) that their non-involvement in handling the warehoused items, and alleged negligence by Customs...(Subscriber-Only)
Issues:
- Did the withdrawal of the warehoused goods without notice to the sureties release petitioners from liability under their general warehousing bonds?
- Does the sureties’ alleged non-involvement in the handling of the warehoused articles, or alleged negligence of Bureau of Customs employees in authorizing withdrawal, relieve petitioners of liability on their bonds?
- Is estoppel applicable to bar the government from collecting the unpaid duties and charges because of ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)