Case Summary (G.R. No. 6668)
Facts of the Case
On October 31, 1961, the heirs of Bienvenido Ferrer and Eduardo Bravo garnished 33 cases of rayon and synthetic textiles that were in the custody of the Collector of Customs. Following garnishment, the textiles were transferred to a bonded warehouse. However, they were erroneously released on December 28, 1963, under forged permits while the goods were still meant to be in custody. The Collector, unaware of the misdelivery, later sought the release of the textiles in 1968, prompting the discovery of the forgery, which led to legal actions against those involved.
Lower Court Rulings
Initially, the trial court ruled that the Collector of Customs was not liable for the loss of the textiles due to the acting sheriff's wrongful actions, deeming the incident a fortuitous event. However, the Court of Appeals reversed this decision, asserting that the negligence of the customs employee in the bonded warehouse made the Collector liable for the misdelivery. This ruling prompted an appeal to the Supreme Court.
Supreme Court Ruling
The Supreme Court upheld the appellate court's ruling, citing precedents which clearly stipulated that a Collector of Customs is officially liable for misdelivery of goods even without personal involvement, under the relevant provisions of the Tariff and Customs Code. The Court referenced the case Lung Chea Kung Kee & Co. vs. Aldanese, emphasizing that statutory provisions hold the Collector personally liable for misdelivery actions taken by subordinates, despite their official capacity.
Petitioner’s Arguments
The Petitioner filed motions for reconsideration arguing that the factual findings that determined his liability were erroneous and that the cited case laws did not apply as stated. The motions suggested that liability should be understood as official rather than personal, which was rejected repeatedly by the Court.
Judgment Finalization and Contempt Motions
After thorough consideration and denial of the motions, the Court affirmed the previous judgments, requiring that the former Collector of Customs José T. Viduya be personally liable for the damages owed to Ferrer and Bravo. Furthermore, a motion of contempt was filed by the respondents against a customs official for allegedly misrepresenting the nature
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Case Background
- The case originated from a motion titled “Urgent Omnibus Petition for Contempt and Clarification/Declaration of Official Liability of the Collector of Customs of Manila” filed by private respondents.
- It references a judgment made by the Supreme Court on June 18, 1985, which affirmed the decision of the Intermediate Appellate Court regarding the liability of the Collector of Customs for misdelivery of cargo.
- The case involves two private respondents, Bienvenido Ferrer and Eduardo Bravo, who garnished 33 cases of rayon and synthetic textiles consigned to Cotabato Palay & Corn Producers, Inc. in 1961 while those textiles were in the custody of the Collector of Customs of Manila.
Facts of the Case
- On October 31, 1961, the garnishment of the textiles took place during the execution pending appeal in Civil Case No. 42189.
- The textiles were transferred to a bonded warehouse on December 19, 1963, by the sheriff, who instructed the warehouseman not to release the goods without his authorization.
- On December 28, 1963, the textiles were released using two delivery permits, allegedly with clearance from the shipping agent and the sheriff, although the sheriff's note was later found to be forged.
- In 1968, the Collector of Customs, unaware of the release, requested the sheriff for the textiles, only to learn they had been released five years prior.
- An investigation by the Nationa