G.R. No. 220211 - Edron Construction Corp. vs. Provincial Government of Surigao del Sur

Provident Tree Farms, Inc. (PTFI) is a Philippine corporation engaged in industrial tree planting that grows gubas trees in its plantations located in Agusan and Mindoro.
PTFI supplies its timber exclusively to a local match manufacturer, relying on the state policy that encourages qualified persons to engage in industrial tree plantation.
Under Section 36, paragraph (1) of the Revised Forestry Code, PTFI is granted incentives which include a qualified ban on the importation of wood and “wood-derivated” products.

A.J. International Corporation (AJIC) imported four containers of matches from Indonesia on 5 April 1989, which were released by the Bureau of Customs on 12 April 1989.
An additional two containers of matches were imported from Singapore on 5 April 1989, with their release recorded on 19 April 1989; however, the exact release date of the second shipment was not disclosed in the records.

On 25 April 1989, at the request of PTFI, Secretary Fulgencio S. Factoran, Jr. of the Department of Natural Resources and Environment issued a certification.
The certification stated that there was an adequate supply of softwood in the Philippines available at reasonable prices for the match industry.

On 5 May 1989, PTFI filed a complaint for injunction and damages with the Regional Trial Court of Manila, docketed as Civil Case No. 89-48836.
PTFI sought a temporary restraining order to prevent AJIC from importing matches and “wood-derivated” products, and also directed the Collector of Customs to impound the said importations.
The relief prayed for included impounding the subject importations and awarding PTFI P250,000.00 in actual damages, P1,000,000.00 in exemplary damages, and P50,000.00 as attorney’s fees.

The exclusive jurisdiction of the Commissioner of Customs under Section 1207 of the Tariff and Customs Code to determine the legality of importations and to handle seizure, detention, or release of property.
The contention that the release of the subject importations rendered the injunction both moot and academic.
The argument that the prayer for damages had no basis since the Commissioner’s acts were lawful, and damages could not be awarded for future conduct.
The claim that the complaint was essentially a provisional remedy rather than a principal one.

The Regional Trial Court initially denied AJIC’s motion to dismiss on 28 July 1989.
On 8 February 1990, after AJIC’s motion for reconsideration and despite PTFI’s opposition, the trial court reversed its earlier order and dismissed the case on the ground that it lacked jurisdiction to determine the legality of importations.

PTFI filed a petition for review seeking to set aside the 8 February 1990 dismissing order and to continue the proceedings in Civil Case No. 89-48836.
PTFI maintained that its complaint for injunction was directed at restraining the entry of safety matches into the country to ensure compliance with Section 36(1) of the Forestry Code, and that the claimed importations constituted a denial of its statutory protection and incentives.
PTFI argued that because it was not an importer, the alternative administrative procedures under R.A. No. 1125 did not apply, thus necessitating judicial intervention.
On the matter of timeliness, although PTFI was alleged to have filed the petition late, it was established that the assailed order was received on 20 February 1990, allowing PTFI until 7 March 1990 to file its petition; an extension was later granted, resetting the deadline to 6 April 1990, on which the petition was filed.

PTFI’s claim was anchored on the statutory incentive under the Revised Forestry Code which mandates a ban on the importation of wood, wood products, or wood-derivated products – a ban that is to be enforced by the Bureau of Customs under the Tariff and Customs Code.
The complaint directly sought judicial orders to impound the imported matches and enjoin AJIC from further importations, effectively challenging the Bureau of Customs’ exclusive jurisdiction over seizure and forfeiture cases.
PTFI also claimed that the absence of an explicit administrative procedure in the Tariff and Customs Code should not bar judicial relief.

The court noted that PTFI’s correspondence with the Bureau of Customs contesting the legality of the match importations suggested an administrative proceeding was already underway.
The principle of primary jurisdiction was invoked, emphasizing that issues requiring special administrative expertise must be resolved by the designated administrative body, not by the courts.
The ultimate relief sought by PTFI – to compel the Bureau of Customs to seize and forfeit the importations – was inherently discretionary and thus not amenable to judicial mandamus unless there was evidence of grave abuse of discretion.

Whether the Regional Trial Court had jurisdiction to compel the enforcement of the import ban mandated by Section 36(1) of the Revised Forestry Code.
Whether the petition for a temporary restraining order to impound the importations and to enjoin AJIC from further imports was an appropriate and proper remedy.
Whether a court can direct the Commissioner of Customs to enforce a prohibition that falls within the exclusive jurisdiction of the Bureau of Customs under the Tariff and Customs Code.
Whether the claim for damages, based on the alleged denial of statutory protection, is premature amid pending administrative determination regarding the legality of the importations.