Facts:

In April 1906, the plaintiffs, Kuenzle & Streiff, imported cotton goods into the Philippine Islands. Upon importation, the Collector of Customs imposed a duty on these goods under paragraph (c) of Article 117 of the applicable tariff laws, which classified the textiles as "plain and without figures, stamped or printed, not measuring over one hundred centimeters in width, weighing 8 kilograms or more per one hundred square meters, and from 26 to 38 threads net weight." In addition to this duty, a surtax of 30 percent was levied under paragraph (g) of the same article. The plaintiffs protested this ruling, arguing that the surtax was illegally imposed. They subsequently appealed the Collector's decision to the Court of First Instance in Manila. After reviewing the evidence, the lower court upheld the Collector's ruling, leading the plaintiffs to appeal to the Supreme Court. The Collector of Customs justified the imposition of the surtax by asserting that...

Facts:

1. Importation of Cotton Goods: In April 1906, the plaintiffs, Kuenzle & Streiff, imported cotton goods into the Philippine Islands.
2. Customs Duty Imposed: The Collector of Customs imposed a duty under paragraph (c) of Article 117 of the tariff laws, along with a 30% surtax under paragraph (g) of the same article.
3. Classification of Goods: The customs authorities classified the goods under paragraph (c) of Article 117 as "textiles, plain and without figures, stamped or printed, not measuring over one hundred centimeters in width, weighing 8 kilograms or more per one hundred square meters, and from 26 to 38 threads net weight."
4. Assessment of Duty: The importation was assessed at 18 cents per kilo, plus a 30% surtax.
5. Protest and Appeal: The plaintiffs protested the imposition of the 30% surtax and appealed the decision of the Collector of Customs to the Court of First Instance of Manila, which affirmed the Collector's ruling. The plaintiffs then appealed to the Supreme Court.

Issue:

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Ruling:

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Ratio:

1. Interpretation of Paragraph (g): The Court interpreted paragraph (g) as imposing a 30% surtax on all textiles mentioned in Article 117 when they are stamped, printed, or manufactured with dyed yarns. This interpretation aligns with the long-standing practice of the customs authorities since November 12, 1901.
2. Long Acquiescence in Customs Regulations: The Court emphasized the principle that long-standing customs regulations, which have been consistently applied and not altered by the Legislature, should be upheld unless there are compelling reasons to the contrary.
3. Applicability to Stamped or Printed Textiles: The Court clarified that paragraph (g) does not apply to textiles described in paragraph 3 of Article 117, which are plain and without figures, not stamped or printed. However, since the imported goods were stamped or printed, the 30% surtax was correctly applied.