Daud v. Collector of Customs
REITERATIONFacts
The Antecedents: Hadji Mohamad Daud was the owner of the motor launch M/L "MISS HURAIRA." On March 23, 1964, the vessel was intercepted by the Philippine Navy for carrying untaxed blue seal cigarettes. The vessel, its crew, and cargo were brought to the custody of the Collector of Customs for the Port of Zamboanga City. Procedural History: The Collector of Customs initiated seizure proceedings (Seizure Identification Case No. 1265 (1149)) against the vessel and cargo, and a criminal case against the crew. On April 27, 1964, the Collector of Customs declared the forfeiture of the vessel and cargo in favor of the Government for violating the Tariff and Customs Code. Hadji Mohamad Daud requested to redeem his vessel on April 28, 1964, pursuant to Section 2307 of the Tariff and Customs Code, clarifying it was not an appeal. On May 12, 1964, the Collector of Customs denied the redemption request, citing a Presidential directive against redeeming smuggled vessels and potential prejudice to criminal prosecution. The Petition: Without appealing the forfeiture decision or the denial of redemption, Hadji Mohamad Daud filed a mandamus suit before the Court of First Instance (CFI) of Zamboanga City, seeking to compel the Collector of Customs to allow redemption. The CFI, after a stipulation of facts, ordered the Collector of Customs to release the vessel upon payment of its appraised value and posting of a bond, with conditions related to its availability for the criminal case. The Collector of Customs appealed this order.
Issue(s)
Whether a regular court possesses jurisdiction to order by writ of mandamus the redemption of a motor vessel forfeited by a Collector of Customs. Whether the Court of First Instance erred in entertaining a mandamus suit to compel the redemption of a forfeited vessel, bypassing the administrative and appellate remedies provided by law.
Ruling
The Supreme Court reversed and set aside the order of the Court of First Instance of Zamboanga City and ordered the dismissal of the mandamus suit. The Court held that the CFI has no jurisdiction over the case.
Ratio Decidendi
On the jurisdiction of regular courts over forfeited vessels: The Court reiterated that Republic Act No. 1125, Section 7, grants the Court of Tax Appeals exclusive appellate jurisdiction to review decisions of the Commissioner of Customs, including those involving seizure, detention, or release of property affected by customs laws. The Collector of Customs, when acting in forfeiture proceedings, constitutes a tribunal whose decisions are appealable first to the Commissioner of Customs and then to the Court of Tax Appeals. Regular courts, such as the Court of First Instance, are divested of the prerogative to interfere with or review these decisions, even through extraordinary remedies like mandamus, prohibition, or certiorari. The Court emphasized that allowing such interference would undermine forfeiture actions. On the procedural path for redemption requests: The Court found that Hadji Mohamad Daud failed to exhaust the administrative and judicial remedies available to him. Instead of appealing the Collector of Customs' forfeiture decision or the denial of his redemption request to the Commissioner of Customs and subsequently to the Court of Tax Appeals, he directly filed a mandamus suit in the Court of First Instance. This bypass of the established procedural hierarchy, which includes the administrative remedies within the Bureau of Customs and the exclusive appellate jurisdiction of the Court of Tax Appeals, rendered the CFI's assumption of jurisdiction erroneous. The Court cited Luna v. Pacis as a similar case where the owner similarly bypassed the proper appellate channels, leading to the dismissal of their mandamus petition by the Court of First Instance.
Main Doctrine
A regular court, specifically a Court of First Instance, does not possess jurisdiction to issue a writ of mandamus to compel the redemption of a vessel forfeited by the Collector of Customs. The exclusive appellate jurisdiction to review decisions of the Collector of Customs lies with the Commissioner of Customs and subsequently the Court of Tax Appeals.