G.R. No. L-15381 - People vs. Maydin

Case Summary (G.R. No. L-15381)

Factual Background

Before the flight departed, the appellant’s person and baggage were examined by Bureau of Customs personnel assigned to outgoing passengers. Customs examiner Benigno Layug questioned the appellant regarding money in her handbag and overnight kit. She stated that she had $100.00, covered by a license, and P100 in Philippine notes. Layug inspected her black handbag and found eight pieces of fifty-peso bills totaling P400.00. When Layug asked why her earlier declaration was limited to $100.00 and P100, the appellant did not answer.

Layug then examined the overnight kit. He noticed that the bottom portion of the kit was unusually elevated and produced a hollow sound when tapped. His suspicion was aroused, and he asked the appellant if she had anything aside from what he had seen. The appellant lightly tapped Layug in a way that caused him to observe her reluctance to continue the examination. Layug requested that she proceed to the Chief Appraiser with the overnight kit, but the Chief Appraiser was not available. The Deputy Collector of Customs, Mr. Crisostomo, arrived and took charge of the examination.

Crisostomo questioned the appellant regarding the contents of the bottom compartment of the overnight kit, and she answered that she had about P10,000.00 there. Because the appellant was anxious to board the plane, Crisostomo permitted her to leave for Hongkong on condition that she leave a representative to witness the opening of the overnight kit. Her husband, Francisco Aldana, acted as the representative. The bottom compartment was opened in the presence of Crisostomo, Aldana, customs agents (including Victorino and Socorro de Guzman), and others, and forty-four pieces of one hundred peso bills, one hundred twenty pieces of fifty peso bills, and four pieces of ten dollars were found, totaling P10,800 and forty dollars in United States currency.

Charges and Trial Court Disposition

Based on the amounts found, the appellant was charged with two violations linked to the lack of Central Bank authority over the currencies in her possession. For carrying and possessing $40 found in her overnight kit without the necessary Central Bank license or permit, as required by section 3(a) of Central Bank circular No. 42 in relation to circular No. 20 and sections 14 and 34 of Republic Act No. 265, she was charged with violation of those provisions. For carrying and possessing P10,800 found in her handbag and overnight kit without the necessary license or permit, as required by section 2(a) of Central Bank circular No. 60 in relation to sections 14 and 34 of Republic Act No. 265, she was charged separately.

After a joint trial, the Court of First Instance of Rizal rendered judgment finding the appellant guilty in both cases. In Criminal Case No. 3825-P, the court sentenced her to six (6) months’ imprisonment, imposed a fine of Three Hundred (P300.00) Pesos, ordered her to pay costs, and declared forfeiture of the four ten-dollar bills (Exhibits “F-1” to “F-4”). In Criminal Case No. 3796-P, the court sentenced her to six (6) months’ imprisonment, imposed a fine of Three Thousand (P3,000.00) Pesos, ordered costs, and declared forfeiture of the fifty-peso bills (Exhibits “C-1” to “C-8” and “D-1” to “D-120”) and the one hundred-peso bills (Exhibits “E-1” to “E-44”), totaling the Philippine currency found.

The Appellant’s Assigned Errors and Legal Arguments

The appellant appealed to the Court of Appeals, which certified the appeal to the Supreme Court due to the purely legal nature of the questions. In her assignments of error, she attacked the validity of the Central Bank regulatory framework and the trial court’s conclusions regarding: (i) the alleged requirement of an “exchange crisis” before the Monetary Board could exercise its powers under Republic Act No. 265, (ii) whether Circular No. 20 required and actually received Presidential approval, (iii) whether subsequent Monetary Board issuances such as Circular No. 42 required separate Presidential approval, (iv) whether Circular No. 42 was truly only supplementary to Circular No. 20, and (v) whether Circular No. 60 likewise required Presidential approval, arguing instead that it was issued under section 14 rather than section 74 of Republic Act No. 265.

She further challenged her criminal liability by contending that she did not violate Circulars Nos. 42 and 60 because she allegedly made an oral declaration to customs authorities that she possessed both the United States currency and Philippine currency. She relied on that alleged declaration to negate the requirement of a license or permit.

Central Bank Circulars, “Exchange Crisis,” and Presidential Approval

The Court held that the Central Bank did not need to declare the existence of an “exchange crisis” before it could exercise powers granted under Republic Act No. 265. The Court reasoned that it was sufficient that the power was exercised to carry out the purpose and aim declared in the law.

The Court also held that the validity of the relevant circulars issued by the Central Bank without any prior declaration of an exchange crisis had been upheld in several earlier decisions cited in the record. It further held that the challenges directed at the legality and validity of Circular No. 20 and the subsequent circulars were already settled in the same line of jurisprudence. The Court stated that Circular No. 20 had the approval of the Chief Executive, and that the subsequent circulars promulgated after Circular No. 20 did not require Presidential approval because they merely implemented Circular No. 20.

Alleged Oral Declaration and Failure to Possess the Required License or Permit

On the appellant’s argument that she did not violate the circulars because she allegedly orally declared the currencies before customs authorities found them, the Court sustained the trial court’s findings of fact. The Court held that the appellant’s pretension was not true. As found by the trial court, she had only declared that she had $100 covered by a license and P100. That admission, made only after the money had been detected, could not substitute for, or take the place of, the license or permit required by law issued by the Central Bank or its authorized agent.

The Court also rejected the appellant’s attempt to invoke a rule discussed in earlier cases, particularly People vs. Lim Ho et al., concerning forfeiture of certain properties. The Court distinguished those cases on evidentiary and procedural grounds

Case Syllabus (G.R. No. L-15381)

The People of the Philippines appealed in prosecutions against Maria Maydin, who was convicted for carrying and possessing specified amounts of foreign and Philippine currency without the Central Bank licenses or permits allegedly required by law.
The Court of Appeals certified the appeal to the Supreme Court because only legal questions were raised, specifically the criminal liability of the appellant under Central Bank Circulars Nos. 42 and 60.
The Supreme Court affirmed the convictions and forfeitures imposed by the trial court.

Parties and Procedural Posture

Maria Maydin stood as the Defendant and Appellant after her joint trial and conviction by the Court of First Instance of Rizal.
The prosecutions were denominated Criminal Case No. 3825-P and Criminal Case No. 3796-P.
The Court of Appeals certified the appeal to the Supreme Court by resolution adopted on 6 March 1959 because only legal questions were presented.
The Supreme Court disposed of the appeal by affirming the judgments appealed from.

Key Factual Allegations

Maria Maydin was booked as an outgoing passenger on a Philippine Air Line plane on February 23, 1956, traveling from Manila to Hongkong.
Shortly before departure, customs officers examined the appellant’s person and baggage at the Manila International Airport at Nichols Air Base, Pasay City.
Customs examiner Benigno Layug asked whether she had money in her handbag and overnight kit (Exhibit “A”), and she answered that she had $100 covered by a license and P100 Philippine notes.
When Layug opened the black handbag, he found eight pieces of fifty-peso bills (Exhibits “C-1” to “C-8”), totaling P400.00.
When questioned why she said she only had $100 and P100, the appellant did not answer.
Layug asked about the contents of the overnight kit (Exhibit “A”), and the appellant replied that it contained only toilet articles and lingeries.
Upon opening the overnight kit, Layug found toilet articles and lingeries, but he suspected concealment because the bottom floor was elevated and produced a hollow sound.
Layug asked whether she had anything aside from what he had seen, and the appellant tapped Layug lightly and caused him to observe that she did not want him to continue the examination.
Layug brought the appellant and the overnight kit to the Deputy Collector of Customs, Mr. Crisostomo, after the Chief Appraiser was not present.
Crisostomo asked the appellant about the bottom compartment contents, and she replied that she had about P10,000.00 therein.
Because the appellant was anxious to leave for the plane, Crisostomo allowed her to depart for Hongkong provided she left a representative to witness the opening of the overnight kit.
The appellant’s husband, Francisco Aldana, served as the representative during the opening.
In the presence of Crisostomo, Aldana, and customs agents, the bottom compartment of Exhibit “A” was opened and yielded concealed cash: forty-four pieces of one hundred peso bills, one hundred twenty pieces of fifty peso bills, and four pieces of ten dollars, totaling P10,800 and forty dollars.
The amounts seized included $40 found in the overnight kit and P10,800 found in the handbag and overnight kit.

Statutory and Circular Basis

The foreign-currency charge was based on the alleged violation of section 3(a) of Central Bank circular No. 42, in relation to circular No. 20 and sections 14 and 34 of Republic Act No. 265.
The Philippine-currency charge was based on the alleged violation of section 2(a) of Central Bank circular No. 60, in relation to sections 14 and 34 of Republic Act No. 265.
The appellant’s liability depended on whether the Central Bank circulars operated without the presidential approval demanded by her theory of statutory delegation and on whether an “exchange crisis” declaration was a prerequisite to the exercise of Central Bank powers.

Appellant’s Assigned Errors

The appellant argued that the trial court erred in concluding that the Monetary Board was empowered by implication to declare the existence of an “exchange crisis” under Republic Act No. 265.
She argued that the trial court erred in concluding that circular No. 20 was approved by the President.
She argued that the trial court erred in holding that subsequent rules and regulations implementing circular No. 20, such as those embodied in circular No. 42, did not require presidential approval.
She argued that the trial court erred in concluding that the rules and regulations in circular No. 42 were me