Case Digest (G.R. No. 36006)
Facts:
- Ang Hok Hin was charged with unlawfully importing merchandise into the Philippines.
- The incident occurred on May 5, 1931, when the steamship President Harrison arrived in Manila.
- The cargo was consigned to Ang Hok Hin and included two packages of canned goods and thirty-four cases of dried cut radish.
- Inspection revealed that twenty-six of the thirty-six cases contained artificial silk textiles instead of the declared goods.
- The prosecution claimed Ang Hok Hin knowingly imported these goods in violation of Section 2702 of the Administrative Code, which penalizes fraudulent importation.
- Evidence showed Ang Hok Hin had a friendly customs inspector and attempted to bribe a customs agent.
- The trial court convicted him, sentencing him to six months imprisonment, a fine of P1,000, and costs.
- Ang Hok Hin appealed, arguing the prosecution failed to prove a violation of Section 2702.
Issue:
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Ruling:
- The Supreme Court acquitted Ang Hok Hin of the charges.
- The Court found the prosecution did not sufficiently prove a violation of Section 2702.
- There was ...(Unlock)
Ratio:
- The Court interpreted Section 2702 of the Administrative Code, which focuses on unlawful importation.
- The statute primarily addresses smuggling, not fraudulent invoicing or misrepresentation after importation.
- Although Ang Hok Hin misrepresented the shipment's contents, the items (silk textiles and dried fish) were not prohibited from importation.
- The legislative intent of Section 270...continue reading
Case Digest (G.R. No. 36006)
Facts:
The case involves Ang Hok Hin, the defendant and appellant, who was charged in the Court of First Instance of Manila for unlawfully importing merchandise into the Philippines. The charge stemmed from an incident on May 5, 1931, when the steamship President Harrison arrived at the port of Manila carrying a shipment consigned to Ang Hok Hin. The cargo included two packages of canned goods and thirty-four cases of dried cut radish, as per the inward foreign manifest filed by the ship's master. However, upon inspection, it was discovered that twenty-six of the thirty-six cases actually contained plain colored and striped artificial silk textiles, rather than the declared dried fish and cuttlefish. The prosecution argued that Ang Hok Hin had willfully and knowingly imported these goods contrary to law, specifically citing Section 2702 of the Administrative Code, which penalizes fraudulent importation. During the trial, evidence was presented that Ang Hok Hin had secured a friendly customs inspector and attempted to bribe a customs agent to avoid scrutiny. The trial court convicted him, sentencing him to six months of imprisonment, a fine of P1,000, and costs of the...