G.R. No. L-26287 - Champion Auto Supply Co., Inc. vs. Bureau of Customs

The appeal revolves around the doctrine of governmental immunity, which protects the Bureau of Customs from being sued without its consent.
This principle is grounded in the understanding that the Bureau operates as part of the national government, specifically in its role as the operator of the Customs Arrastre Service.
The precedent set in the case of Mobil Philippines Exploration, Inc. vs. Customs Arrastre Service establishes that there is no statute allowing for such suits against the Bureau.

Champion Auto Supply Company, Inc. filed a complaint against the Bureau of Customs, alleging negligence leading to the loss of goods while in the Bureau's custody.
The plaintiff claimed that a shipment of eight bundles of cone and oil pump assembly was lost or short-delivered due to the Bureau's negligence, resulting in damages amounting to P10,094.25.
The plaintiff sought recovery of the lost amount along with legal interest and attorney's fees.

The Bureau of Customs denied the allegations and asserted several defenses, including its immunity from suit and the lack of jurisdiction of the court over the money claim against the government.
The Bureau highlighted that the plaintiff did not comply with the requirements set forth in Act No. 3083, as amended, which governs claims against the government.

After the presentation of evidence, the trial court dismissed the case due to the plaintiff's failure to prove that the shipment was delivered in good order to the Bureau.
The court noted the absence of necessary documentation, such as cargo or tally sheets, to substantiate the plaintiff's claims.
The plaintiff's motion for reconsideration was denied, leading to the appeal.