Collector of Customs v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the importation of a sizeable amount of tobacco by businessman Jesus G. De Jesus. Customs authorities refused to process the importation, citing a violation of law and the absence of required documents. De Jesus's attempts to secure the release of the tobacco were unsuccessful, leading him to seek judicial intervention. 2. Procedural History: De Jesus filed a Petition for injunction, prohibition, and mandamus with the Court of First Instance of Manila (Civil Case No. 83572) against the Collector of Customs, Commissioner of Customs, and Secretary of Finance. The trial court ruled in favor of De Jesus on May 15, 1972. The Solicitor General, representing the customs authorities, alleged receipt of the decision on May 25, 1972, and filed a Notice of Appeal on June 23, 1972. However, the trial court found that the Solicitor General was served on May 23, 1972, rendering the appeal untimely. The trial court denied a motion for reconsideration and issued a writ of mandamus for the release of the tobacco. The Solicitor General then elevated the case to the Court of Appeals (CA-G.R. No. 01347) via a Petition for certiorari, prohibition, and mandamus. The Court of Appeals, in a decision promulgated on January 23, 1973, ruled that the appeal was filed out of time, sustained the trial court's findings, and dismissed the petition. 3. The Petition: This case is before the Supreme Court on a Petition for certiorari under Rule 45 of the Rules of Court, filed by the Collector of Customs, Commissioner of Customs, and Secretary of Finance, represented by the Solicitor General. The core argument is that the Solicitor General received the trial court's decision on May 25, 1972, not May 23, 1972, as found by the Court of Appeals, thereby making the Notice of Appeal timely. The petitioners seek a review of the Court of Appeals' decision, which affirmed the trial court's finding that the appeal was not perfected within the reglementary period. The private respondent argues that the petition raises only factual issues, which are generally beyond the scope of a Rule 45 certiorari petition.
Issue(s)
Whether the Supreme Court can review the factual finding of the Court of Appeals regarding the date of receipt of the trial court's decision. Whether the appeal was perfected within the reglementary period.
Ruling
The petition is denied for lack of merit. The Supreme Court is bound by the findings of fact of the Court of Appeals, absent any showing that such findings are totally devoid of support in the record or constitute a grave abuse of discretion. The petitioners failed to perfect an appeal within the reglementary period, rendering the trial court's decision final and executory.
Ratio Decidendi
On the issue of reviewing factual findings: The Supreme Court reiterated its ruling that only questions of law may be raised in a petition for certiorari under Rule 45. The Court does not re-examine the facts of a case in such petitions, except for unusual reasons. In this case, the Solicitor General's argument assails a finding of fact by the Court of Appeals – the date of receipt of the trial court's decision. The Supreme Court is bound by the Court of Appeals' findings of fact unless the Solicitor General satisfactorily demonstrates that these findings are totally devoid of support in the record or are so glaringly erroneous as to constitute a serious abuse of discretion. The petitioners failed to provide such a demonstration. On the perfection of appeal: The core of the controversy lies in the date the Solicitor General received the trial court's decision. The Court of Appeals, after examining the record, found that the Solicitor General received the decision on May 23, 1972. Under the then-existing Rules of Court, a 30-day period was provided for appeal. If received on May 23, 1972, the notice of appeal filed on June 23, 1972, was filed beyond the reglementary period. Consequently, the decision of the trial court had become final and executory. The perfection of an appeal within the reglementary period is mandatory and jurisdictional. Failure to do so renders the decision final and executory, making it a ministerial duty of the court to order its execution.
Main Doctrine
A petition for certiorari under Rule 45 of the Rules of Court is limited to questions of law, and the Supreme Court does not re-examine facts found by the Court of Appeals, absent any compelling reason such as a finding that is totally devoid of support in the record or constitutes a grave abuse of discretion.