Case Digest (G.R. No. L-27360) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Papa et al. v. Mago et al. (G.R. No. L-27360, February 28, 1968), petitioners Hon. Ricardo G. Papa (Chief of Police of Manila), Hon. Juan Ponce Enrile (Commissioner of Customs), Pedro Pacis (Collector of Customs, Port of Manila) and Patrolman Martin Alagao sought to annull an order of Hon. Hilarion U. Jarencio, Branch 23, Court of First Instance (CFI) of Manila, authorizing the release under bond of nine bales of imported goods. On November 4, 1966, Alagao, acting on deputation by Commissioner Enrile and under Chief Papa’s orders, intercepted two trucks leaving the customs zone at Agrifina Circle and seized their cargo of misdeclared and undervalued goods. Claimant Remedios Mago, alleging she purchased the goods in good faith and that the seizure lacked a search warrant, filed Civil Case No. 67496 in the CFI for mandamus, preliminary injunction and damages, joined by Valentin Lanopa (owner of the trucks). The trial court issued an ex parte restraining order, inventory was mad Case Digest (G.R. No. L-27360) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and underlying petition
- Petitioners: Ricardo G. Papa (Chief of Police, Manila), Juan Ponce Enrile (Commissioner of Customs), Pedro Pacis (Collector of Customs, Port of Manila), Martin Alagao (Manila Police patrolman).
- Respondents: Remedios Mago (claimant of goods), Hilarion U. Jarencio (Presiding Judge, Branch 23, CFI Manila).
- Seizure of goods
- November 3–4, 1966: Lt. Martin Alagao, acting on police‐customs intelligence and under deputation from Commissioner Enrile, intercepted two trucks at Agrifina Circle carrying nine bales of alleged misdeclared personal effects.
- Goods accompanied by an “Informal Entry” receipt in the name of Bienvenido Naguit; seized for undervaluation and misdeclaration under the Tariff and Customs Code.
- Proceedings in Civil Case No. 67496 (CFI Manila)
- November 9, 1966: Mago and Valentin Lanopa filed a petition for mandamus and preliminary injunction alleging illegal seizure without warrant, wrongful detention of trucks and goods, and prayed for return of property and damages.
- November 10, 1966: Judge Jarencio issued an ex parte restraining order against opening the bales; interim inventory and examination proceeded despite order.
- December 9–13, 1966: Inventory of contents made; Mago filed motion (Dec. 23) to release goods upon bond. Petitioners filed oppositions and raised: lack of CFI jurisdiction, exclusive CTA jurisdiction, non-exhaustion of administrative remedies, and insufficiency of bond.
- March 7, 1967: Judge Jarencio ordered release of goods to Mago upon posting of ₱40,000 bond; bond posted March 13. Petitioners moved for reconsideration and then filed certiorari/prohibition with SC.
Issues:
- Jurisdictional scope
- Did the Court of First Instance have jurisdiction over imported goods seized and held under customs custody?
- Did the issuance of a warrant of seizure and identification by the Collector of Customs oust any purported CFI jurisdiction?
- Legality of search, seizure, and release
- Were the warrantless interception and seizure by Manila Police lawful under the Tariff and Customs Code?
- Did Judge Jarencio act with jurisdiction in ordering the release of the goods upon bond?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)