G.R. No. 138081, March 30, 2000
- Regional Trial Courts are devoid of any competence to pass upon the validity or regularity of seizure and forfeiture proceedings conducted by the BOC and to enjoin or otherwise interfere with these proceedings.
FACTS:
On December 9, 1998, Felipe Bartolome, District Collector of Customs of Cebu, issued a Warrant of Seizure and Detention of 25,000 bags of rice, bearing the name of “SNOWMAN, Milled in Palawan.” According to the EIIB, the rice was landed in Palawan by a foreign vessel and then placed in sacks marked “SNOWMAN, Milled in Palawan.” It was then shipped to Cebu City on board the vessel M/V “Alberto.” Forfeiture proceedings were commenced but respondents filed a complaint for injunction with the RTC of Cebu City, impugning the issuance of the Warrant.
The RTC ruled in favor of respondents and ordered the return of the goods. Meanwhile, in the forfeiture proceedings before the Collector of Customs of Cebu, a decision was rendered ordering the goods forfeited in favor of the government.
ISSUE:
- Whether or not the RTC has jurisdiction to pass upon the validity of seizure and forfeiture proceedings
HELD:
There is no question that Regional Trial Courts are devoid of any competence to pass upon the validity or regularity of seizure and forfeiture proceedings conducted by the BOC and to enjoin or otherwise interfere with these proceedings. The Collector of Customs sitting in seizure and forfeiture proceedings has exclusive jurisdiction to hear and determine all questions touching on the seizure and forfeiture of dutiable goods. The Regional Trial Courts are precluded from assuming cognizance over such matters even through petitions for certiorari, prohibition or mandamus.
The rule that RTCs have no review powers over such proceedings is anchored upon the policy of placing no unnecessary hindrance on the government’s drive, not only to prevent smuggling and other frauds upon Customs, but more importantly, to render effective and efficient the collection of import and export duties due the State, which enables the government to carry out the functions it has been instituted to perform.
Even if the seizure by the Collector of Customs were illegal, such act does not deprive the BOC of jurisdiction thereon.
