G.R. No. 101761 - National Sugar Refineries Corp. vs. National Labor Relations Commission

The case involves the appellant, Maria Maydin, who was an outgoing passenger on a Philippine Air Line flight from Manila to Hongkong on February 23, 1956.
Prior to the flight’s departure at the Manila International Airport in Pasay City (Nichols Air Base), Maria Maydin and her baggage underwent an inspection by personnel from the Bureau of Customs.

Customs examiner Benigno Layug was assigned to examine Maydin’s luggage, which included a black handbag and an overnight kit (designated Exhibit "A").
During the inspection of her handbag, Layug discovered eight pieces of fifty-peso bills (Exhibits "C-1" to "C-8") amounting to a total of P400.
When asked about her belongings in the overnight kit, the defendant initially stated that it contained only toilet articles and lingeries.
A suspicious hallow sound emanating from the high-bottom compartment of the overnight kit prompted further inquiry.
When Layug attempted to further inspect the compartment, Maydin tapped him lightly, signaling her reluctance to continue the examination.
The overnight kit was then taken to the Deputy Collector of Customs, Mr. Crisostomo, who, in the presence of representatives including Maydin’s husband Francisco Aldana, examined its contents.

Upon opening the bottom compartment of Exhibit "A" in the presence of several customs officials and the defendant’s representative:

The total monetary value found in the overnight kit amounted to P10,800 and $40.
Earlier, Maydin had also declared that she possessed $100 (covered by a license) and P100, a statement that was inconsistent with the quantities and values actually discovered.

For carrying and having in her possession $40 without the necessary Central Bank license or permit (as required by section 3(a) of Central Bank Circular No. 42 in relation to Circular No. 20 and sections 14 and 34 of Republic Act No. 265).
For carrying and having in her possession P10,800 without the required license or permit as mandated by section 2(a) of Central Bank Circular No. 60 in relation to sections 14 and 34 of Republic Act No. 265.

The case was tried in the Court of First Instance of Rizal.
In Criminal Case No. 3825-P, Maria Maydin was sentenced to six (6) months imprisonment, fined P300, and ordered to pay court costs, with the four ten-dollar bills declared forfeited.
In Criminal Case No. 3796-P, she received a sentence of six (6) months imprisonment, a fine of P3,000, payment of court costs, and the forfeiture of the peso bills (exhibits "C-1" to "C-8", "D-1" to "D-120", and "E-1" to "E-44").

Maria Maydin appealed the decision, contesting the legality of the lower court’s conclusions and the subsequent issuance of Central Bank Circulars.
The appellant argued that the lower court erred in finding that the Monetary Board of the Central Bank could, by implication, validate the existence of an "exchange crisis" through subsequent circulars.
The appeal also questioned the necessity of Presidential approval for Circulars Nos. 42 and 60, asserting that her verbal declarations should have sufficed in lieu of a formal license.

Whether the defendant, Maria Maydin, violated provisions of the Central Bank’s Circulars Nos. 42 and 60 by carrying and possessing currency without the required license or permit.
Whether the issuance of Circulars Nos. 42 and 60 by the Central Bank without an explicit declaration of an "exchange crisis" is legally valid and within the power granted to it by Republic Act No. 265.
Whether subsequent circulars (post-Circular No. 20), which implement and supplement an initially approved circular, require further Presidential approval for their validity.
Whether the defendant’s assertion of having verbally declared her possession of the currency could replace the statutory requirement of possessing an official license or permit.
Whether the forfeiture of the currency found in Maydin’s possession was properly executed as per the evidence and applicable legal standards.