SUBIC BAY METROPOLITAN AUTHORITY vs. RODRIGUEZ- Customs Tax

FACTS:

On September 29, 2001, a shipment described as “agricultural product” arrived at Subic Bay Freeport Zone. On October 23, the BOC issued a Memorandum stating that upon examination the shipment was found to contain rice. The representative of the importer then stated that there was a “misshipment” and manifested willingness to pay appropriate duties and taxes. The BOC then  issued a Hold Order on October 25, 2001. Despite several certifications for its clearance, Petitioner SBMA refused to allow the release of the rice shipment. Hence, on June 11, 2002, the respondent-importers filed with the RTC of Olongapo City a complaint for Injunction and Damages against SBMA.

ISSUE:

Did the RTC have jurisdiction over the case?

HELD:

NO. The Collector of Customs has exclusive jurisdiction over seizure and forfeiture proceedings and the regular courts can not interfere nor can it enjoin these proceedings. This is the rule the moment the imported goods are in the possession or control of the Customs authorities even if no warrant for seizure or detention had previously been issued. The actions of the BOC are then only appealed to the CTA. The Court also said that this rule, which is anchored upon the policy of placing no unnecessary hindrance on the government’s drive to prevent smuggling and fraud and to collect correct duties, is absolute.