Title
Walter E. Olsen and Co., Inc. vs. Aldanese
Case
G.R. No. L-18740
Decision Date
Apr 28, 1922
A dispute over export certification for cigars, where the Collector of Internal Revenue's refusal, based on unauthorized requirements, was deemed invalid, leading to a writ of mandamus in favor of the exporter.
A

Case Summary (G.R. No. L-18740)

Petitioner’s Claim and Relief Sought

The petitioner sought a writ (mandamus) compelling the Collector of Internal Revenue to issue a certificate of origin for a consignment (10,000 machine-made cigars) so that the cigars could be admitted into the United States free of customs duties. The petition relied on provisions of Act No. 2613 (1916) authorizing the Collector of Internal Revenue to inspect and certify tobacco as standard for export and to certify its Philippine origin to the Insular Collector of Customs, who would then issue the necessary certificate of origin.

Respondents’ Pleadings and Procedural Posture

Respondents’ demurrer to the petition was overruled on March 29, 1922; an answer was filed on April 3, and the petitioner moved for judgment on the pleadings on April 21. The answer admitted several factual allegations in the petition (including statutory and regulatory provisions pleaded in paragraphs 4, 5, 6, and 7) but interposed defenses asserting discretionary authority and denying that the petition established a right to the requested certificate.

Relevant Statutory and Regulatory Provisions

Act No. 2613 (1916)—“An act to improve the methods of production and the quality of tobacco in the Philippines and to develop the export trade therein”—specifically empowers the Collector of Internal Revenue to promulgate rules for classification, marking, packing, and inspection of tobacco for domestic sale or export, and authorizes certification of standard tobacco as Philippine-grown to facilitate duty-free admission into the United States. Administrative Order No. 35 (Tobacco Inspection Regulations), promulgated under clause B of section 6 of Act No. 2613, defines “standard” cigars to include requirements such as manufacture under sanitary conditions, use of good selected tobacco, a crop harvested at least six months prior, and a requirement that cigars be manufactured exclusively from the product of the provinces of Cagayan, Isabela, or Nueva Vizcaya and be “long filler” cigars.

Factual Admissions Concerning the Cigars

The parties’ pleadings, as characterized by the court, effectively admit that the cigars presented by petitioner were machine-made, short-filler cigars manufactured with tobacco that was not exclusively the product of Cagayan, Isabela, or Nueva Vizcaya. The Collector of Internal Revenue, upon receiving the petitioner’s application on or about February 6, 1922, accepted petitioner’s representation that the cigars were short-filler and not grown in the three provinces, and on that basis declined to inspect and refused to issue the certificate of origin.

Respondents’ Special Defense Regarding Discretion

Respondents asserted as a special defense that the Collector of Internal Revenue possessed discretionary power under section 11 of Act No. 2613 and section 5 of the Administrative Code of 1917 to decide whether manufactured tobacco met the requisites of Administrative Order No. 35. They further contended that it was within the Collector’s discretion whether to inspect and certify manufactured tobacco and that the courts lacked jurisdiction to compel issuance of the certificate unless, after inspection, the Collector found the tobacco compliant.

Legal Question Presented

Whether, under the admitted facts, the Collector’s refusal (based on the asserted nonconformity of the cigars with Administrative Order No. 35) constituted a lawful exercise of discretion that could be pleaded as a defense to the petitioner’s request for a writ compelling issuance of a certificate of origin.

Court’s Analysis of the Admissions and Grounds of Refusal

The court observed that because the answer admitted the specific grounds for refusal—that the cigars were not long-filler and were not manufactured from tobacco grown in one of the three specified provinces—the defendants were confined to those specified grounds and could not rely on other unpled grounds for refusal. The court treated the answer’s statements as an effective admission that the Collector rejected the request for the sole stated reasons.

Administrative Order No. 35 and Prior Ruling

The court noted that the respondents’ refusal was based upon portions of Administrative Order No. 35 that, according to a prior opinion of the court referenced in the record, had been held null and void. Given that the Collector promulgated and acted under those regulations, the court reasoned that the Collector's refusal was in effect a refusal pursuant to regulations the court had previously invalidated.

Demand and Futility Doctrine in Mandamus Practice

Relying on established mandamus practice, the court explained that a formal demand for performance is not required where (i) the officer’s conduct demonstrates a settled purpose not to perform the duty, or (ii) making the demand would be a vain and useless formality. The court cited authorities to the effect that

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