Case Digest (G.R. No. L-15381)
Facts:
People of the Philippines v. Maria Maydin, G.R. Nos. L-15381-82. April 26, 1961, the Supreme Court, Padilla, J., writing for the Court. The respondent-appellant Maria Maydin was an outgoing passenger booked on Philippine Air Lines on February 23, 1956, from Manila to Hongkong. At the Manila International Airport (Nichols Air Base) customs examiners inspected her handbag and overnight kit. Examiner Benigno Layug found eight fifty-peso bills (P400) in her handbag and, upon further inspection of the overnight kit after questioning and the arrival of Deputy Collector Crisostomo, discovered a hidden compartment containing forty-four one-hundred peso bills, one hundred twenty fifty-peso bills and four ten-dollar bills, totaling P10,800 and $40. Maydin’s husband acted as her representative when the kit was opened.Maydin was charged in two criminal cases: (1) Criminal Case No. 3825-P — possession of $40 without the Central Bank license required by Central Bank Circular No. 42 (sec. 3(a)) in relation to Circular No. 20 and ss. 14 & 34 of Republic Act No. 265; and (2) Criminal Case No. 3796-P — possession of P10,800 without the permit required by Circular No. 60 (sec. 2(a)) in relation to ss. 14 & 34 of R.A. No. 265. After a joint trial the Court of First Instance of Rizal convicted Maydin in both cases, imposing six-month terms, fines (P300 and P3,000), costs, and forfeiture of the seized currency as specified in the judgments.
Maydin appealed to the Court of Appeals. Because only legal questions were raised, the Court of Appeals, by resolution of March 6, 1959, certified the appeals to the Supreme Court for decision. The issues certified involved the validity and scope of the Central Bank’s circulars (including...(Pro-only)
Issues:
- Was the appeal properly certified by the Court of Appeals to the Supreme Court (procedural mode of review)?
- Whether the Monetary Board of the Central Bank must first declare the existence of an “exchange crisis” before exercising powers under R.A. No. 265 (procedural-substantive).
- Whether Central Bank Circular No. 20 required presidential approval and whether subsequent circulars (Nos. 42 and 60) required separate presidential approval to be valid.
- Whether Maydin committed the offenses charged under Circulars Nos. 42 and 60 and R.A. No. 265 by carrying the seized foreign and Philippine currency without the required license or permit.
- Whether ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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