Case Digest (G.R. No. 209830)
Facts:
Mitsubishi Motors Philippines Corporation v. Bureau of Customs, G.R. No. 209830, June 17, 2015, the Supreme Court First Division, Perlas-Bernabe, J., writing for the Court.The respondent Bureau of Customs (BOC) filed a collection suit for unpaid taxes and customs duties totaling P46,844,385.00 against petitioner Mitsubishi Motors Philippines Corporation (Mitsubishi) before the Regional Trial Court (RTC) of Manila, Branch 17 (Civil Case No. 02-103763), alleging that Mitsubishi used tax credit certificates (TCCs) fraudulently obtained by third parties to settle duties on importations in 1997–1998. The BOC claimed a post-audit by the Department of Finance revealed the TCCs were procured through fake commercial and bank documents; Mitsubishi countered that it acquired the TCCs in good faith from their original holders and that the certificates were authentic.
The RTC initially dismissed the case on May 17, 2005 for the continuous absence of the respondent’s counsel. The Court of Appeals (CA), in CA-G.R. SP No. 97301, reinstated the action in a June 27, 2008 Decision; Mitsubishi sought relief from the Court in G.R. No. 186106, but the Supreme Court denied the petition in a February 23, 2009 Resolution. Trial resumed before the RTC. After the BOC presented evidence, Mitsubishi filed a Demurrer to Plaintiff’s Evidence on February 10, 2012. The RTC, by Order dated April 10, 2012, granted the demurrer and dismissed the collection suit for insufficiency of proof that Mitsubishi participated in fraud; a motion for reconsideration was denied on August 3, 2012.
The BOC filed a Notice of Appeal to the CA on August 28, 2012. In CA-G.R. CV No. 99594 the CA issued Resolutions dated June 7, 2013 and November 4, 2013 referring the records to the Court of Tax Appeals (CTA) for proper disposition, acknowledging it lacked jurisdiction but opting to refer rather than dismiss in deference...(Pro-only)
Issues:
- Did the Court of Appeals have jurisdiction to refer the records of the collection case to the Court of Tax Appeals instead of dismissing the appeal?
- If the CA lacked jurisdiction, is the RTC’s April 10, 2012 dismissal final and executory because the Bureau of Customs availed of the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)