Development Bank of the Philippines v. Court of Appeals
REITERATIONFacts
The Antecedents: The Development Bank of the Philippines (DBP) imported IBM computer equipment and paid P5,562,926.00 in customs duties, compensating taxes, and import processing fees. DBP sought a refund under Section 4(c) of Executive Order No. 1087, but the Commissioner of Customs refused, asserting the duties were correctly imposed. Procedural History: DBP appealed to the Court of Tax Appeals (CTA), which ruled in its favor, ordering the refund. The Commissioner of Customs appealed to the Supreme Court (G.R. No. 79635), but the case was referred to the Court of Appeals (CA) due to the latter's exclusive appellate jurisdiction over CTA cases under Batas Pambansa Bilang 129 (BP 129). In the CA, the Commissioner's position was sustained; the CA annulled the CTA decision, holding that the dispute was not within the CTA's jurisdiction but should have been settled administratively under Presidential Decree No. 242 (PD 242). The CA reasoned that PD 242, a later enactment, superseded Section 7(2) of Republic Act No. 1125 (RA 1125) concerning the settlement of disputes between government entities. The Petition: DBP filed a petition for review on certiorari with the Supreme Court, arguing that (1) the Court of Appeals lacked jurisdiction to review CTA decisions, which pertained exclusively to the Supreme Court, and (2) the CA erred in applying PD 242 to the controversy.
Issue(s)
Whether the Court of Appeals has exclusive appellate jurisdiction over decisions of the Court of Tax Appeals. Whether Presidential Decree No. 242 supersedes Republic Act No. 1125 regarding the settlement of disputes between government entities, specifically concerning customs duties.
Ruling
The petition is denied for lack of merit. The Supreme Court affirms the challenged Decision of the Court of Appeals.
Ratio Decidendi
On Issue 1: The Court reaffirms its earlier resolution that the Court of Appeals, under Section 9 of Batas Pambansa Bilang 129, now possesses exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders, or awards of quasi-judicial agencies, instrumentalities, boards, or commissions, including the Court of Tax Appeals. While the CTA was not explicitly reorganized by BP 129, the law's broad and comprehensive provisions expanded the CA's appellate jurisdiction to cover such bodies. Therefore, appeals from the CTA to the Court of Appeals should be taken via notice of appeal cum petition for review, consistent with Republic Act No. 5434. On Issue 2: The Court rejects DBP's argument that the CA erred in applying PD 242. It upholds the CA's conclusion that there is an "irreconcilable repugnancy" between Section 7(2) of RA 1125 and PD 242 concerning the manner of settlement of disputes involving customs duties between government offices, agencies, and corporations. Following the rule of statutory construction that a later enactment prevails over an earlier one when they are irreconcilably contradictory on the same subject matter, PD 242, being the later expression of legislative will, should govern. Thus, the dispute between DBP and the Commissioner of Customs should have been administratively settled or adjudicated under PD 242, as it was not a case already pending in court at the time of PD 242's effectivity.
Main Doctrine
The Court of Appeals, by virtue of Batas Pambansa Bilang 129, exercises exclusive appellate jurisdiction over final judgments, decisions, resolutions, orders, or awards of quasi-judicial agencies, including the Court of Tax Appeals. This jurisdiction supersedes prior laws that vested such appellate power in the Supreme Court, emphasizing that later enactments, when irreconcilably repugnant with earlier ones on the same subject, prevail as the latest expression of legislative will. Consequently, disputes between government entities, even those involving customs duties, must be settled or adjudicated according to the procedures outlined in Presidential Decree No. 242 if they fall within its scope, unless already pending in court prior to its effectivity.