Case Digest (G.R. No. 128064)
Facts:
R.V. Marzan Freight, Inc. v. Court of Appeals and Shielas Manufacturing, Inc., G.R. No. 128064, March 04, 2004, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.
The petitioner, R.V. Marzan Freight, Inc. (a customs-bonded warehouse operator), stored merchandise for third parties at its bonded premises; the private respondent, Shielas Manufacturing, Inc., was the consignee and importer of a shipment of raw materials valued at US$32,006.93 that arrived on April 12, 1989. Philippine Fire and Marine Insurance Corporation (Philfire) issued an insurance policy covering the petitioner's warehouse and stocks-in-trade.
The shipment was not immediately released because the consignee did not file the required import entry and did not claim the cargo. Sea-Land Service, Inc. authorized the petitioner to take delivery of the container for stripping and safekeeping. The Bureau of Customs initiated Abandonment Proceedings No. 288-89; a notice was posted on the Bureau's bulletin board on September 29, 1989, but no separate notice was sent to Shielas because ICTSI's records allegedly showed the consignee's address as unknown. A Law Division memorandum later informed auction authorities that the declaration of abandonment had become final and executory as of October 30, 1989.
While preparations for inventory and sale were pending, part of the petitioner's warehouse burned on July 26, 1990, destroying Shielas' goods. Philfire paid P12,000,000 to Shielas. On March 19, 1991 Shielas demanded payment from R.V. Marzan for the shipment's value, but the petitioner refused; R.V. Marzan also executed a Release of Claim and Hold Harmless Undertaking on October 28, 1991.
Shielas filed a complaint before the Regional Trial Court (RTC) of Pasig, Branch 154, on December 26, 1991, seeking US$32,006.93 (or peso equivalent), attorneys’ fees and costs from R.V. Marzan and Philfire. The petitioner pleaded lack of privity, asserted that the cargo had been declared abandoned and thus ipso facto became government property under the Tariff and Customs Code, invoked fortuitous event/act of God and due care defenses, and maintained bonded-warehouse status as an extension of the Bureau of Customs. Philfire moved to dismiss for lack of contractual obligation to Shielas and asserted it had already settled its liability.
At trial the petitioner produced Atty. Leonardo S. Doctor of the Bureau of Customs to show the abandonment declaration. The RTC found that Shielas had not been validly notified as required by Section 1801 of the Tariff and Customs Code and thus the Collector’s declaration was ineffective; it held R.V. Marzan solely liable for the loss, awarding US$32,006.93 (with interest), P30,000 attorneys’ fees and costs, and dismissed the claims against Philfire. The trial court reasoned that the insurance procured by the bonded warehouse inured to the benefit of owners of the stored property and that bonded warehouses remain only an extension of the Bureau of Customs for as long as they are storing goods.
R.V. Marzan appealed to the Court of Appeals (CA-G.R. CV No. 49905), which affirmed the RTC on January 31, 1997, holding the Collector failed to give the required notice and that posting on the bulletin board was insufficient where the consignee’s address was known or discoverable. ...(Pro-only)
Issues:
- Did the Regional Trial Court have jurisdiction to review and declare ineffective the District Collector of Customs' declaration in Abandonment Proceedings No. 288-89 that the shipment was abandoned?
- If the RTC lacked such jurisdiction, did Shielas still have a valid cause of action against R.V. Marzan for the value of t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)