People v. Maydin
REITERATIONFacts
The Antecedents: Maria Maydin was an outgoing passenger from Manila to Hong Kong. During a customs examination, she declared having $100.00 covered by a license and P100.00 in Philippine notes. However, a search of her handbag revealed P400.00, and a subsequent examination of her overnight kit, which she claimed contained only toilet articles and lingerie, uncovered a hidden compartment. Upon inquiry, she stated she had about P10,000.00 in the compartment. Procedural History: Deputy Collector of Customs Crisostomo allowed Maydin to depart for Hong Kong after she left her husband as representative, with the condition that her overnight kit would be opened. The kit was opened in the presence of customs officials and her husband, revealing P10,800.00 and $40.00. Maydin was charged with violations of Central Bank Circulars Nos. 42 and 60 for possessing foreign and local currency without the necessary license or permit. The Court of First Instance of Rizal found her guilty and sentenced her to six months imprisonment and fines for each violation, with forfeiture of the currency. The Petition: Maydin appealed her conviction to the Court of Appeals, which certified the case to the Supreme Court due to the purely legal questions raised concerning the validity and applicability of the Central Bank circulars and the extent of the Monetary Board's powers.
Issue(s)
Whether the Central Bank must declare an 'exchange crisis' before exercising regulatory powers under Republic Act No. 265. Whether Central Bank Circulars Nos. 42 and 60 are invalid for lack of individual presidential approval. Whether the trial court had the authority to order the forfeiture of the seized Philippine and United States currency.
Ruling
The judgments of the Court of First Instance of Rizal finding Maria Maydin guilty of violating Central Bank Circulars Nos. 42 and 60 are affirmed. The forfeiture of the currency is also affirmed.
Ratio Decidendi
On Issue 1: The Court ruled that the Central Bank of the Philippines does not need to declare the existence of an exchange crisis before exercising the powers granted to it by Republic Act No. 265. It is sufficient that the power be exercised to carry out the purposes and aims declared in the law. Prior jurisprudence has already upheld the validity of circulars promulgated without such a prior declaration. The authority of the Monetary Board is derived from the broad mandate of the Central Bank Act to maintain monetary stability. Therefore, the absence of a specific crisis declaration does not invalidate the regulations issued. On Issue 2: The Court held that Central Bank Circular No. 20 was duly approved by the Chief Executive. Circulars promulgated subsequent to Circular No. 20, such as Circular No. 42, do not require separate presidential approval because they are merely implementing or supplementary rules. Circular No. 60 was issued under Section 14 of Republic Act No. 265, which does not necessitate presidential approval for its validity. The appellant's admission of possessing the money only after detection cannot serve as a substitute for the required license. Consequently, the circulars used as the basis for the conviction are legally valid and binding. On Issue 3: The forfeiture of the bills was declared legal because they were presented in evidence and were under the control of the trial court. The Court distinguished this case from People v. Lim Ho, where forfeiture was handled by customs because the items were not introduced in evidence at the criminal trial. In the present case, the currency was seized, marked, and offered as evidence during the joint trial. As instruments of the crime within the court's jurisdiction, the trial judge was empowered to order their forfeiture in favor of the government. This judicial forfeiture is distinct from administrative proceedings initiated by the Collector of Customs.
Main Doctrine
The Central Bank need not declare an exchange crisis to exercise its powers under Republic Act No. 265. Subsequent circulars implementing a primary circular do not require presidential approval for their validity. Failure to declare possession of foreign and local currency, despite oral declarations made after detection, constitutes a violation of Central Bank circulars, and forfeiture of the undeclared currency is legal.