Case Summary (G.R. No. L-15381)
Facts Surrounding the Incident
The customs inspection of Maria Maydin revealed discrepancies in her declarations regarding the amount of money she was carrying. Initially, Maydin stated that she possessed $100 and P100. However, further inspection revealed that she had an additional P400 in her handbag and was eventually found to possess P10,800 and $40 after examining her overnight kit. The customs authorities charged her for violating Central Bank circulars concerning the handling of currency without appropriate licenses or permits.
Legal Charges and Trial Outcome
Maria Maydin was charged under Section 3(a) of Central Bank Circular No. 42 and Section 2(a) of Circular No. 60, in relation to Sections 14 and 34 of Republic Act No. 265, for carrying U.S. dollars and Philippine pesos without the necessary licenses. The Court of First Instance of Rizal found Maydin guilty, sentencing her to six months' imprisonment and fines totaling P3,300, along with the forfeiture of the seized currency.
Appeal's Grounds and Legal Issues
On appeal, Maydin contended that the lower court erred in various conclusions, particularly regarding the power of the Monetary Board of the Central Bank to declare an "exchange crisis" and the requirement for presidential approval for the validity of the circulars. She argued that Circular No. 20 lacked approval and that subsequent circulars should also be invalid for lack of such endorsement.
Court's Position on Monetary Board's Authority
The court upheld that the Central Bank need not declare an exchange crisis to exercise its powers under Republic Act No. 265. The court referenced previous cases that supported the validity of the circulars issued by the Central Bank without necessitating prior declaration of an exchange crisis.
Validity of Circulars and Presumptions of Compliance
The court found that Circular No. 20 was indeed approved by the Chief Executive, while later circulars, being supplemental to Circular No. 20, did not require separate presidential approval. The court concluded that those circulars were legally valid and enforceable.
Rulings on Alleged Violations and Requirements for Licensure
Addressing Maydin's defense regarding her declaration of currency, the court noted that he
...continue readingCase Syllabus (G.R. No. L-15381)
Background of the Case
- The case involves the appeal of Maria Maydin, who was charged with violating Central Bank regulations regarding the possession of foreign and Philippine currency without the necessary licenses.
- The appeal was certified to the Supreme Court by the Court of Appeals, focusing solely on legal questions concerning the criminal liability of the appellant under Central Bank Circulars Nos. 42 and 60.
Facts of the Case
- Maria Maydin was an outgoing passenger on a Philippine Air Lines flight from Manila to Hong Kong on February 23, 1956.
- Prior to departure, her person and baggage were inspected by customs personnel at Manila International Airport.
- During the inspection, customs examiner Benigno Layug inquired about the amount of money in Maydin’s possession. She initially declared having $100 covered by a license and P100.
- Upon examination of her handbag, Layug discovered eight fifty-peso bills totaling P400, raising suspicions about her initial statement.
- When asked about her overnight kit, Maydin claimed it contained only toilet articles and lingerie. However, the examiner detected a hollow sound from the kit and requested further inspection.
- The Deputy Collector of Customs, Mr. Crisostomo, arrived and permitted Maydin to leave for Hong Kong, provided her husband stayed behind as a representative for the inspection.
- The subsequent search reveal