Case Digest (G.R. No. L-23996)
Facts:
The case revolves around a prohibition proceeding initiated by Pedro Pacis, the Acting Collector of Customs for the Port of Manila. The respondent, Manuel R. Pamaran, served as the Assistant City Fiscal of Manila, and Ricardo Santos is the other respondent, owning a Mercury automobile which was the subject of the conflict. The incident in question traces back to when Santos imported the vehicle, which was exempted from customs duties when owned by Donald James Hatch. However, when Santos acquired the vehicle, he subsequently paid only P311.00 in customs duties on June 25, 1964, despite outstanding duties claimed to be around P2,500.00. Following a reported discrepancy regarding the payment, Pacis issued a warrant of seizure and detention for Santos's vehicle on July 22, 1964, believing he acted correctly within his official capacity.
On discovering that Santos's vehicle was described as a "hot car" by the authorities, Pacis conducted the seizure without a subs
Case Digest (G.R. No. L-23996)
Facts:
- Background and Parties
- Petitioner:
- Pedro Pacis, acting as Collector of Customs for the Port of Manila, who exercised his administrative powers in enforcing customs laws.
- Respondents:
- Manuel R. Pamaran, then Assistant City Fiscal of Manila, tasked with the preliminary investigation of criminal complaints.
- Ricardo Santos, owner of a Mercury automobile, involved due to issues with customs duty payment.
- Customs Duty and the Automobile
- The automobile involved was a Mercury, model 1957, acquired by respondent Santos.
- It was brought into the country with an alleged discrepancy in customs duties:
- An amount of P311.00 was paid by Santos, whereas the proper duty collectible was approximately P2,500.00.
- A record from the Administrator, General Affairs Administration of the Department of National Defense, indicated that the vehicle was classified as a "hot car."
- Seizure Proceedings
- On July 22, 1964, petitioner, relying on the “hot car” report, verified the discrepancy in the duty payment and initiated seizure proceedings.
- He issued a warrant of seizure and detention for the automobile.
- The warrant was executed by agents of the Department of National Defense, resulting in:
- The vehicle’s seizure while it was parked on Economia Street, Manila.
- The automobile being brought to the General Affairs Administration compound.
- Respondent Santos’ Reaction and Subsequent Actions
- On August 26, 1964, respondent Santos (through counsel) requested the withdrawal or dissolution of the seizure warrant, asserting its unauthorized nature.
- Santos claimed that the issuance of the warrant violated constitutional provisions regarding search and seizure—that only a judge (under the 1935 Constitution) could issue such a warrant.
- He threatened to initiate criminal proceedings against the petitioner for usurpation of judicial functions under Article 241 of the Revised Penal Code.
- The Criminal Complaint and Prohibition Action
- On August 31, 1964, petitioner responded denying the request for the vehicle’s release and affirmed that his actions were well within his legal authority.
- On September 15, 1964, respondent Santos filed a criminal complaint for usurpation of judicial functions with the City Fiscal, which was assigned to Manuel R. Pamaran for preliminary investigation.
- The petitioner, contesting the continuation of the investigation and the very premise of usurpation, instituted a prohibition suit to bar the prosecution, emphasizing that his administrative actions were authorized under customs laws.
Issues:
- Jurisdiction and Authority
- Whether the petitioner, as Collector of Customs, possessed the statutory authority to issue the warrant of seizure and detention without judicial intervention.
- Whether such issuance of a seizure warrant, pursuant to customs law, amounts to the usurpation of judicial functions as charged in the criminal complaint.
- Constitutional and Statutory Concerns
- Whether the procurement and execution of the warrant of seizure violated constitutional protections against unreasonable searches and seizures by bypassing the judicial requirement.
- Whether the statutory provisions of the Tariff and Customs Code expressly empower customs officials to conduct seizures without a judicial warrant, thereby nullifying the claim of constitutional infringement.
- Practical Implications of Enforcement
- How a criminal prosecution for usurpation might deter customs officials from diligently enforcing the law.
- Whether the administrative safeguards and legal doctrines provide sufficient protection for the statutory actions of customs officers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)