Case Summary (G.R. No. L-30391)
Factual Background
The petitioners exported raw sugar to the United States using private wharves, Sto. Nino Wharf in Bacolod City and the Philippine Bulk Corporation wharf in Pulupandan, without utilizing any government port facilities. The Collector of Customs for the Port of Iloilo imposed and collected wharfage dues based on sections 2801 and 2802 of the Tariff and Customs Code after the petitioners paid these dues under protest. The petitioners' subsequent appeal to the Tax Court was dismissed, leading to an appeal to the Supreme Court by the petitioners.
Legal Framework
The key legal provisions at issue are sections 2801 and 2802 of the Tariff and Customs Code, as amended, which define wharfage dues and provide the applicable rates for exported articles. The wharfage dues are defined as a charge against the cargo of a vessel engaged in foreign trade, calculated based on the quantity, weight, or measure of cargo received or discharged. It is important to note that these sections allow for the collection of wharfage dues even when private wharves are utilized for loading or unloading commodities.
Appellants’ Argument
The petitioners contended that the wharfage fees collected were unjustifiable since they exported their sugar exclusively through private wharves, asserting that the definition of wharfage implies a charge for the use of governmental facilities. They cited various precedents, arguing that wharfage is fundamentally a fee for utilization of a wharf or harbor, and therefore should not apply to their circumstances as they incurred no costs for government facilities.
Court’s Analysis
The Court rebuffed the petitioners' interpretation of wharfage, noting that the Tariff and Customs Code does not restrict the collection of wharfage dues solely to situations involving government-owned wharves. The definition of wharfage, as interpreted in prior rulings, extends beyond mere use of a wharf to encompass charges against the cargo itself, applicable regardless of location—be it offshore, midstream, or private wharves.
Historical Precedents
The ruling reaffirmed the Court's long-standing interpretations concerning wharfage dues, citing cases like Philippine Sugar Centrals Agency vs. Insular Collector of Customs, where similar stances were supported. The
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Case Overview
- The case involves the legality of wharfage dues amounting to P904,236.38 collected by the Commissioner of Customs from the petitioners in relation to their exportation of sugar from private wharves.
- The petitioners are five corporations that exported raw sugar to the United States from two private wharves located in Bacolod City and Pulupandan, Negros Occidental.
- The wharfage dues were collected despite the fact that no government port facilities were utilized for the shipments.
Facts of the Case
- Between 1959 and 1966, the petitioners shipped raw sugar to the United States.
- The shipments were loaded at the Sto. Nino Wharf and the wharf of the Philippine Bulk Corporation, both of which are privately owned.
- The Collector of Customs for the Port of Iloilo assessed wharfage dues based on sections 2801 and 2802 of the Tariff and Customs Code, which the petitioners paid under protest.
- The Collector dismissed the petitioners' protest, leading to an appeal to the Commissioner of Customs, who affirmed the Collector's decision.
- The petitioners subsequently filed a petition for review with the Court of Tax Appeals, which was dismissed due to lack of cause of action.
Legal Issues
- The petitioners challenged the Tax Court's dismissal of their case and contended that wharfage dues should not apply because they did not use any government facilities d