Case Summary (G.R. No. 246343)
Applicable Law
The case is decided under prevailing regulations from the 1987 Philippine Constitution, along with Republic Act No. 1937, or the Tariff and Customs Code of the Philippines (TCCP).
Antecedents of the Case
In 2013, JBFLI entered multiple rice importation transactions. Upon arrival at the Manila International Container Port (MICP), BOC refused to release the shipments, asserting that JBFLI lacked the necessary import permit from the National Food Authority (NFA). This prohibition initiated two parallel proceedings: one in the Regional Trial Court (RTC) and another within the BOC.
Proceedings Before the Regional Trial Court
JBFLI filed a Petition for Declaratory Relief and Permanent Injunction with the RTC, challenging the import permit requirement and arguing it had no basis following the expiration of special treatment under the World Trade Organization Agreement. The petition sought various forms of injunctive relief against the enforcement of NFA resolutions requiring such permits.
Proceedings Before the Bureau of Customs
While the RTC case was pending, JBFLI requested the MICP District Collector to lift alert orders on its rice shipments. JBFLI later indicated a preference for the issuance of Warrants of Seizure and Detention (WSD) against the shipments, leading to the issuance of WSDs by the District Collector on July 21, 2014. Subsequently, JBFLI sought release of the shipments under cash bond, which the District Collector ignored, ultimately announcing a public auction for the shipments.
Proceedings Before the Court of Tax Appeals
JBFLI responded to the District Collector's auction notice by filing a Petition for Review in the CTA, arguing that it had been denied due process and that the auction prejudiced its rights. The CTA granted a Temporary Restraining Order (TRO) against the auction, but it expired before a writ of preliminary injunction could be issued, leading to the auction occurring anyway.
Decisions of the Court of Tax Appeals
The CTA held that it had jurisdiction over JBFLI’s petition and ruled that the rice importations did not require permits. The auction proceedings were ultimately deemed moot, as the rice shipments had already been auctioned. In subsequent proceedings, the CTA en banc affirmed this decision, dismissing the BOC's petition for review and ordering the release of auction proceeds to JBFLI.
Appeals and Final Rulings
The BOC's petitions for reconsideration were denied, maintaining that the required votes to overturn prior rulings were not obtained. The principal issues addressed included whether the CTA Third Division could engage JBFLI’s petition amid the ongoing RTC case and whether JBFLI had committed forum shopping. The Court ruled favorably for JBFLI on both counts, asserting that the auction’s conduct by the District C
...continue readingCase Syllabus (G.R. No. 246343)
Introduction
- The case involves a Petition for Review on Certiorari filed by the Bureau of Customs (BOC) and the Commissioner of Customs against Jade Bros. Farm and Livestock, Inc. (JBFLI).
- The petition challenges the July 4, 2018 Decision and April 2, 2019 Resolution of the Court of Tax Appeals (CTA) en banc in CTA EB Case No. 1566.
- The CTA en banc affirmed previous rulings that confirmed the legality of JBFLI's rice imports, despite differing findings from the CTA Third Division.
Antecedents
- In 2013, JBFLI, a domestic corporation engaged in agricultural product trading, began rice importation transactions.
- Upon arrival at the Manila International Container Port (MICP), the BOC refused to release the shipments, citing a lack of import permits from the National Food Authority (NFA).
- This refusal led to parallel proceedings: JBFLI's Petition for Declaratory Relief in the Regional Trial Court (RTC) and administrative actions by the BOC.
Proceedings before the Regional Trial Court
- On February 13, 2014, JBFLI filed a Petition for Declaratory Relief and Permanent Injunction with the RTC of Manila, claiming the import permit requirement was unfounded post-World Trade Organization agreements.
- JBFLI sought various forms of injunctive relief against the petitioners, including:
- Immediate issuance of a Temporary Restraining Order (TRO).
- Permanent injunction against requiring import permits for rice.
- Prevention of any seizure or auction of rice shipments.
Proceedings before the Bureau of Customs
- While the RTC case was pending, JBFLI requested the MICP District Collector t