G.R. No. L-4447 - Murphy, Morris and Co. vs. Collector of Customs of the Philippine Islands

In September 1904, Murphy, Morris & Co. imported paper labels (wrappers) used for cigars and cigar boxes into the Philippine Islands.
The labels in question were produced lithographically and were meant for commercial use, impacting the classification and tariff rate applied.

The Collector of Customs classified the imported labels under subdivision (d) of paragraph 183 of Act No. 230 (Tariff Revision Law of 1901), which imposed a rate of 80 cents per kilo based on their classification as having more than thirteen printings.
The plaintiffs contended that the labels should be classified under subdivision (c) of the same paragraph, for items with eight to thirteen printings, which carried a lower rate of 40 cents per kilo.

Analysis of the labels revealed that they exhibited ten colors with bronze, the latter counted as equivalent to three printings, thus allegedly constituting thirteen printings.
A raised, embossed appearance on portions of the label prompted the critical question: whether embossing should be counted as an additional “printing” under the tariff provisions.

The Collector of Customs based the classification on the interpretation that “printing” referred to the number of impressions or times the article was run through the press—even if no ink was used (in the case of embossing).
The Collector’s decision, after rejecting the protest of Murphy, Morris & Co., was affirmed by the Court of Customs Appeals.
After the decision of the Court of Customs Appeals was lost from the record and transferred to the Court of First Instance, Judge A. S. Crossfield restated and reaffirmed the original decision on October 25, 1907.
The record in both appellate instances primarily relied on the physical evidence (i.e., copies of the labels) without further substantive proof adduced at the hearing.

Paragraph 183 of the Tariff Revision Law of 1901 differentiates between labels based on the number of “printings”:

Subdivision (c) applies to labels with eight to thirteen printings (with bronze printing counted as three printings) at a rate of 40 cents per kilo.
Subdivision (d) applies to labels with more than thirteen printings, or those printed in whole or in part in metal leaf, at a rate of 80 cents per kilo.

The labels, having ten distinct colors plus bronze (counted as three colors) and an embossed surface, were deemed by the administrative authorities to meet the criteria for having more than thirteen printings.

The labels’ design details (colors, bronze treatment, and embossing) were crucial in the determination of the number of “printings.”
Administrative and lower court interpretations rested on established precedents and dictionary definitions, which extended the meaning of “printing” to include impressions produced by embossing.
The primary evidence was the visual and physical characteristic of the labels, with no additional contradictory evidence presented during proceedings.

Whether the embossed (raised) appearance on the labels can be legally and technically regarded as a “printing” under paragraph 183 of the Tariff Revision Law.
Whether the labels should be classified as having eight to thirteen printings (thus attracting a lower tariff rate) or as having more than thirteen printings (attracting a higher tariff rate).
How the term “printing” should be interpreted in the context of the tariff law, particularly when considering processes that do not use ink but involve pressure (embossing).