Case Summary (G.R. No. 104604)
Factual Background
On August 10, 1990, the Bureau of Customs' Enforcement and Security Services received a tip-off about untaxed vehicles and parts located at two premises owned by a person named Pat Hao. Following surveillance, Maj. Jaime Maglipon recommended the issuance of warrants for seizure and detention. The District Collector of Customs issued the warrants on August 13, 1990, leading to a search of the premises. The petitioners filed an injunction and damages case against the customs officials after their vehicles and parts were subject to seizure.
Legal Proceedings Initiated
Petitioners filed their case, Civil Case No. 90-2382, before the Regional Trial Court of Makati on August 27, 1990. The trial court granted a Temporary Restraining Order (TRO) against the respondents on the same day. Despite the respondents' motion to dismiss the case on the grounds of lack of jurisdiction, the trial court denied this motion on November 20, 1990. A preliminary injunction was later issued, which prohibited the respondents from seizing and selling the vehicles.
Court of Appeals Decision
Respondents appealed to the Court of Appeals, asserting that the Regional Trial Court lacked jurisdiction over the seizure and forfeiture proceedings, which they claimed are exclusively under the jurisdiction of the Bureau of Customs. On October 6, 1995, the Court of Appeals reversed the trial court's decision and dismissed the civil case, highlighting that Regional Trial Courts cannot interfere in such matters.
G.R. No. 111223 - Ombudsman Proceedings
In G.R. No. 111223, the petitioners filed criminal complaints against the respondents, alleging violations of domicile and robbery among other offenses. The Ombudsman dismissed these complaints for lack of merit, prompting the petitioners to seek reconsideration, which was also denied. The petitioners argued that the Ombudsman failed to acknowledge key evidence against the respondents.
Conclusions on Jurisdiction and Claims
The Supreme Court affirmed the Court of Appeals’ decision in G.R. No. 104604, underscoring that the Collector of Customs has exclusive jurisdiction over seizure and forfeiture. Petitioners’ claims regarding their properties and the legality of the seizure must be addressed within the Bureau of Customs. The Court
...continue readingCase Syllabus (G.R. No. 104604)
Case Background
- The case involves two petitions: G.R. No. 104604 and G.R. No. 111223, filed by Narciso O. Jao and Bernardo M. Empeynado against various respondents including the Court of Appeals and various officials of the Bureau of Customs.
- G.R. No. 104604 is a petition for certiorari regarding the decision of the Court of Appeals which set aside certain orders of the Regional Trial Court of Makati in Civil Case No. 90-2382.
- G.R. No. 111223 pertains to a petition for certiorari against the Ombudsman, concerning the dismissal of criminal charges filed by the petitioners against the respondents.
Facts of the Case
- On August 10, 1990, the Bureau of Customs received intelligence regarding untaxed vehicles and parts located at two premises owned by Pat Hao.
- Following surveillance, Major Jaime Maglipon recommended the issuance of warrants of seizure and detention.
- On August 13, 1990, District Collector Titus Villanueva issued the warrants.
- During the execution of these warrants, Customs personnel faced resistance at the Makati location, leading to amended warrants being issued on August 15, 1990.
- Petitioners filed for an injunction against the seizure in Civil Case No. 90-2382, and the trial court granted a Temporary Restraining Order.
- The trial court later denied the respondents' motion to dismiss based on jurisdic