Case Summary (G.R. No. 70648)
Overview of the Case
The Commissioner of Customs seeks the reversal of a decision made by the Court of Tax Appeals concerning Campos Rueda Corporation, which had claimed a refund for overpaid customs duties on three separate importations. The case primarily revolves around the legality of the customs duties reassessment made by the Bureau of Customs.
Factual Background
Campos Rueda Corporation imported tungsol flashers and sealed beams from the United States from 1973 to 1974. The merchandise was re-appraised by the Bureau of Customs at higher values than those declared by the corporation based on an "Alert Notice" from Finance Attaches. The corporation paid the corresponding taxes and duties, amounting to substantial sums and subsequently filed protests for refunds which were denied by the Collector of Customs. The corporation then appealed to the Commissioner of Customs, who upheld the denial.
Ruling of the Court of Tax Appeals
Upon appeal, the Court of Tax Appeals found that the assessment of customs duties violated Section 201 of the Tariff and Customs Code. It highlighted that while the Commissioner of Customs had re-appraised the values based on an "Alert Notice," there was no evidence that this notice was presented during administrative proceedings or that it complied with the statutory requirements. The Court ultimately ruled in favor of Campos Rueda Corporation, ordering the refund of overpaid customs duties.
Legal Basis for Determination of Dutiable Values
Section 201 of the Tariff and Customs Code defines that the dutiable value of imported articles should primarily be derived from the home consumption value or price mentioned in the relevant invoices. It allows for re-appraisal based on additional reliable data where there is reasonable doubt regarding the declared values. Importantly, it mandates the publication of home consumption values to inform and guide importers.
Non-Compliance with Assessments
The Court noted the Bureau of Customs' reliance on the "Alert Notice" without having disclosed its contents or the rationale for the reassessment to Campos Rueda Corporation or the court. The lack of transparency
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Case Information
- Deciding Body: Second Division of the Supreme Court of the Philippines
- Decision Date: July 31, 1987
- G.R. No.: 70648
Parties Involved
- Petitioner: Commissioner of Customs
- Respondents: Court of Tax Appeals and Campos Rueda Corporation
Procedural History
- The case originated from CTA Case No. 2830, where Campos Rueda Corporation sought a refund from the Commissioner of Customs for overpaid customs duties on its importations.
- The Court of Tax Appeals ruled in favor of Campos Rueda Corporation, prompting the Commissioner of Customs to seek a reversal of this decision.
Factual Background
Campos Rueda Corporation imported tungsol flashers from the United States:
- Two shipments were received, one on November 1, 1973, worth $10,812.20 and another on February 12, 1974, worth $18,220.10.
- The Bureau of Customs re-appraised these shipments at $1.08 per piece, leading to increased duties of P18,591.00 and P52,226.00 respectively.
- Protests were filed (Manila Protests Nos. 9274 and 9275) for refunds of the excess amounts paid.
Another importation involved sealed beams, with a shipment arriving on March 31, 1974, valued at $18,964.54:
- The invoiced price was $0.908 per piece, but the Collector of Customs re-appraised it to $1.35 per piece, resulting in duties of P67,525.00.
- A protest (Manila Protes