Case Digest (G.R. No. 220502)
Facts:
In Steel Corporation of the Philippines v. Bureau of Customs, et al., G.R. No. 220502, February 12, 2018, the Supreme Court Second Division, Peralta, J., writing for the Court, denied the petition for review on certiorari. The petition challenged the Court of Appeals' November 19, 2014 Decision and September 15, 2015 Resolution in CA‑G.R. SP No. 127046, which had affirmed the Regional Trial Court of Balayan, Batangas' June 6, 2012 Order dissolving a writ of preliminary injunction and dismissing a complaint for lack of jurisdiction.On September 11, 2006, Equitable PCI Bank, Inc. filed a petition for rehabilitation of Steel Corporation of the Philippines (STEELCORP) before the RTC of Batangas City; the RTC issued a stay on claims against STEELCORP on September 12, 2006. After the Financial Rehabilitation and Insolvency Act (R.A. No. 10142) took effect in 2010, Section 19 provided that taxes and fees due to the national government and LGUs are waived upon issuance of a Commencement Order until approval of a rehabilitation plan. The Municipality of Balayan waived its taxes for STEELCORP beginning 2011. STEELCORP sought to invoke Section 19 as to national taxes and customs duties after the Bureau of Customs (BOC) assessed import duties and VAT amounting to P41,206,120.
Beginning October 2010, Commissioner Angelito A. Alvarez of the BOC initially approved a waiver, but the Department of Finance (DOF) undersecretary issued a May 26, 2011 indorsement disapproving on grounds that (1) the RTC stay was not the Commencement Order required by law and (2) the waiver did not cover imports made after the Commencement Order. STEELCORP elevated the dispute to the Office of the President (O.P. No. 11‑F‑211). DOF moved to dismiss for lack of jurisdiction, invoking the Court of Tax Appeals' exclusive review under Section 2315 of the Tariff and Customs Code and R.A. No. 1125, as amended.
On September 14, 2011 STEELCORP filed Civil Case No. 5042 for injunction with a TRO before the RTC, Br. 10 of Balayan, Batangas. The RTC granted a 72‑hour TRO (later extended) and, on January 12, 2012, ordered the MICP District Collector to release STEELCORP's imported raw materials without payment. The Office of the Solicitor General (OSG) filed a Motion to Dismiss on January 12, 2012, asserting lack of jurisdiction and the availability of exclusive remedies before the Court of Tax Appeals (CTA). On March 5, 2012 the RTC denied the motion to dismiss and issued a writ of preliminary injunction on March 8, 2012; subsequently, after motions for reconsideration and related pleadings, the RTC on June 6, 2012 granted the OSG and BIR motions, set aside the January 12 and March 5 orders, dissolved the WPI, and denied STEELCORP's motion for execution.
STEELCORP's motion for reconsideration was denied September 17, 2012. It appealed to the Court of Appeals under Rule 41. The CA dismissed the appeal on November 19, 2014, upholding (a) the RTC's substantial compliance with the procedural notice requirements for motions and (b) the CTA's exclusive jurisdiction over tax and cu...(Subscriber-Only)
Issues:
- Did the trial court and the Court of Appeals err in giving due course to the OSG's and BIR's motions despite alleged noncompliance with Sections 5 and 7, Rule 15 of the Rules of Court (notice of hearing and motion day)?
- Did the trial court have jurisdiction to issue injunctive relief enjoining the BOC and BIR from assessing and collecting national taxes and customs duties when appeals and administrative indorsements concerning customs/customs decisions fall within the exclusive jurisdiction of the Court o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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