G.R. No. L-29218 - Viduya vs. Berdiago

Petitioner Jose T. Viduya, then Collector of Customs of Manila, initiated a seizure and detention proceeding against private respondent Eduardo Berdiago (alias Eduardo Bertiago) based on the alleged use of fraudulent documents.
The dispute centered on a Rolls Royce car (Model 1966, 2 door Hardtop with Motor No. CRX 1379) imported into the Philippines, which was misdeclared as a 1961 model to drastically reduce the customs duty payable.
The correct customs duty for the car was P219,783.00, yet Berdiago paid only P3,255.00, evidencing an underpayment due to misrepresentation.

The misdeclaration and underpayment were discovered prior to the issuance of any search warrant.
A warrant of seizure and detention was issued on the basis that fraudulent documents were used to secure the erroneous customs clearance.
After a formal demand for the payment of the deficient amount, respondent Berdiago expressed willingness to pay but failed to comply effectively, prompting the issuance of Seizure Identification Case No. 10941 against the vehicle.
The vehicle was found in a dwelling house at the Yabut Compound, Wakas, Barrio San Dionisio, Paranaque, Rizal.

Two officers of the Customs Police Service, acting as duly authorized agents of petitioner, applied for a search warrant to search the dwelling house and seize the car pursuant to Section 2209 of the Tariff and Customs Code.
The search warrant was issued by respondent Judge on May 30, 1968.
Respondent Berdiago moved to quash the search warrant on June 3, 1968, invoking his constitutional right against unreasonable search and seizure due to a supposed lack of probable cause.
An opposition to the motion was filed on June 6, 1968 by petitioner, emphasizing that under the circumstances and the prior discovery of misdeclaration, there was sufficient probable cause.
Despite the presence of reliable intelligence and existing seizure proceedings, respondent Judge quashed the search warrant, an act later challenged in the certiorari and mandamus proceeding.

The case was contextualized with prior decisions, notably Papa v. Mago and Carroll v. United States, which provided persuasive support for the approach taken by customs authorities.
Legal principles regarding the enforcement of customs laws, especially the importance of collecting the proper duties and preventing smuggling or fraudulent practices, were emphasized.
The petitioner’s action was further supported by established policies mandating strict enforcement of tariff and customs laws to prevent revenue losses.
The factual record showed that even though the search warrant was issued later than the warrant of seizure and detention, the underlying probable cause had been clearly established.

Whether respondent Judge’s quashing of the search warrant constituted a grave abuse of discretion in light of the already established probable cause.
Whether the observed sequence—where the search warrant was issued after facts creating probable cause had been documented—justifies the issuance of such a warrant despite its delayed application.

Whether the constitutional right against unreasonable search and seizure applies with the same rigor in customs enforcement cases involving dutiable articles.
If the protection afforded to a person’s private effects is diminished when applied to goods subject to seizure and forfeiture under customs laws.

Whether the Tariff and Customs Code, particularly Section 2209, authorizes search and seizure in a dwelling house when the goods in question may not be the personal property of the respondent.
Whether the inherent state power to enforce revenue laws and prevent fraud trumps the procedural requirements typically observed in warrant issuance.