Asian Terminals, Inc. v. Bautista-Ricafort
REITERATIONFacts
The Antecedents: Importers Noel Tabuelog, et al. imported 72 secondhand right-hand drive buses from Japan. The Bureau of Customs impounded the vehicles and ordered their sale at public auction. The Secretary of Justice later issued an opinion stating that shipments loaded and exported before February 22, 1998, were not covered by RA No. 8506, unless loaded and imported after said date. Procedural History: The importers filed a complaint for replevin with damages against customs officials. The RTC granted the writ of replevin. Despite obstruction, the Sheriff took custody of the vehicles after the importers paid taxes, duties, and charges. The Bureau of Customs and Asian Terminals, Inc. (ATI) filed an Omnibus Motion and Third-Party Claim, respectively, questioning the RTC's jurisdiction and asserting a lien for storage and arrastre charges. The RTC dismissed the complaint, stating it had no jurisdiction over seizure and confiscation cases, which fall under the exclusive appellate jurisdiction of the Court of Tax Appeals. The RTC also dismissed ATI's Complaint-in-Intervention, stating it was accessory to the principal case and that the vehicles should be returned to the Bureau of Customs. ATI appealed to the Court of Appeals (CA), which affirmed the RTC's dismissal, ruling that the RTC lacked jurisdiction over the main case and thus over the intervention. ATI then filed a petition for review on certiorari with the Supreme Court. The Petition: Asian Terminals, Inc. (ATI) seeks the reversal of the CA decision, arguing that the CA erred in dismissing its third-party claim/complaint-in-intervention based on the dismissal of the main action and the RTC's lack of jurisdiction over the principal action.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion in dismissing the complaint for replevin, considering the Bureau of Customs' exclusive jurisdiction over seizure and forfeiture proceedings. Whether the Regional Trial Court committed grave abuse of discretion in dismissing the complaint-in-intervention filed by Asian Terminals, Inc., given the lack of jurisdiction over the principal action. Whether the Court of Appeals erred in affirming the dismissal of the complaint-in-intervention, considering the ancillary nature of intervention.
Ruling
The petition is denied for lack of merit. The Court of Appeals decision affirming the dismissal of the RTC is affirmed. The RTC acted in accordance with law and jurisprudence when it issued the assailed Orders.
Ratio Decidendi
On the RTC's jurisdiction over the replevin case: The Court reiterated that Regional Trial Courts are devoid of any competence to pass upon the validity or regularity of seizure and forfeiture proceedings conducted by the Bureau of Customs and to enjoin or otherwise interfere with these proceedings. The Collector of Customs exercises exclusive jurisdiction over such matters. Therefore, the RTC should have dismissed the petition for replevin at the outset, as it acted without jurisdiction. The initial orders of the RTC granting the writ of replevin and its implementation are void. Even if the District Collector of Customs allowed the release of the vehicles upon payment of taxes, this did not vest jurisdiction on the RTC to take cognizance of the replevin petition. The forfeiture of seized goods is a proceeding in rem, directed against the property itself, and the Bureau of Customs has exclusive jurisdiction over it. On the RTC's jurisdiction over the complaint-in-intervention: Considering that the RTC had no jurisdiction over the respondents' action for replevin and over the shipment subject of the complaint, all proceedings before it were void. Consequently, the RTC had no jurisdiction to take cognizance of ATI's complaint-in-intervention and act thereon, except to dismiss it. Intervention is merely ancillary and supplemental to the existing litigation and is never an independent action. The dismissal of the principal action necessarily results in the dismissal of the complaint-in-intervention. A court that lacks jurisdiction over the principal action also lacks jurisdiction over a complaint-in-intervention, as intervention presupposes the pendency of a suit in a court of competent jurisdiction. Therefore, the RTC did not err in dismissing ATI's complaint-in-intervention. On the Court of Appeals' decision: The dismissal of the principal action necessarily results in the dismissal of the complaint-in-intervention. A court that lacks jurisdiction over the principal action also lacks jurisdiction over a complaint-in-intervention, as intervention presupposes the pendency of a suit in a court of competent jurisdiction. Therefore, the RTC did not err in dismissing ATI's complaint-in-intervention, and the Court of Appeals did not err in affirming this dismissal.
Main Doctrine
Regional Trial Courts are devoid of jurisdiction to pass upon the validity or regularity of seizure and forfeiture proceedings conducted by the Bureau of Customs, and to enjoin or otherwise interfere with these proceedings. The Collector of Customs, sitting in seizure and forfeiture proceedings, has exclusive jurisdiction. Consequently, a court which has no jurisdiction over the principal action has no jurisdiction over a complaint-in-intervention.