Asian Terminals V Ricafort - Case Syllabus

Asian Terminals, Inc. vs. Bautista-Ricafort, 505 SCRA 748, G.R. No.
166901 October 27, 2006
Taxation; Tariff and Customs Code; Jurisdictions; The Bureau of Customs exercises exclusive jurisdiction
over seized and forfeited cars—it is tasked to enforce tariff, and supervise and control customs law and all other laws,
rules and regulations relating to the tariff and customs administration, and to supervise and control all import and export
cargoes, loaded or stored in piers, terminal facilities, including container yards and freight stations, for the protection of
government revenues.—We rule that the trial court acted in accordance with the Tariff and Customs Code (TCC) and
the rulings of this Court when it issued the assailed Orders. Section 602 of the TCC provides that the Bureau of
Customs shall exercise exclusive jurisdiction over seized and forfeited cars. It is tasked to enforce tariff, and supervise
and control customs law and all other laws, rules and regulations relating to the tariff and customs administration; and
to supervise and control all import and export cargoes, loaded or stored in piers, terminal facilities, including container
yards and freight stations, for the protection of government revenues. Under Section 2301 of the TCC, the Collector of
Customs is empowered to make a seizure of cargoes and issue a receipt for the detention thereof.
Same; Same; Same; Courts; Regional Trial Courts; 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.—As the Court ruled in Jao v. Court of Appeals, 249
SCRA 35 (1995), 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. It is the Collector of Customs, sitting in seizure and forfeiture proceedings, who has exclusive jurisdiction
to hear and determine all questions touching on the seizure and forfeiture of dutiable goods. The Regional Trial Courts
are precluded from assuming cognizance over such matters even through petitions of certiorari, prohibition or
mandamus. The Court further explained: It is likewise well-settled that the provisions of the Tariff and Customs Code
and that of Republic Act No. 1125, as amended, otherwise known as “An Act Creating the Court of Tax Appeals,”
specify the proper fora and procedure for the ventilation of any legal objections or issues raised concerning these
proceedings. Thus, actions of the Collector of Customs are appealable to the Commissioner of Customs, whose
decision, in turn, is subject to the exclusive appellate jurisdiction of the Court of Tax Appeals and from there to the
Court of Appeals. The rule that Regional Trial Courts have no review powers over such proceedings is anchored upon
the policy of placing no unnecessary hindrance on the government’s drive, not only to prevent smuggling and other
frauds upon Customs, but more importantly, to render effective and efficient the collection of import and export duties
due the State, which enables the government to carry out the functions it has been instituted to perform.
Same; Same; Same; The forfeiture of seized goods in the Bureau of Customs is a proceeding against the
goods and not against the owner—it is in the nature of a proceeding in rem, i.e., directed against the res or imported
articles and entails a determination of the legality of their importation.—The RTC had no jurisdiction to take cognizance
of the petition for replevin by respondents herein, issue the writ of replevin and order its enforcement. The Collector of
Customs had already seized the vehicles and set the sale thereof at public auction. The RTC should have dismissed
the petition for replevin at the outset. By granting the plea of respondents (plaintiffs below) for the seizure of the
vehicles and the transfer of custody to the court, the RTC acted without jurisdiction over the action and the vehicles
subject matter thereof. It bears stressing that the forfeiture of seized goods in the Bureau of Customs is a proceeding
against the goods and not against the owner. It is in the nature of a proceeding in rem, i.e., directed against the res or
imported articles and entails a determination of the legality of their importation. In this proceeding, it is, in legal
contemplation, the property itself which commits the violation and is treated as the offender, without reference
whatsoever to the character or conduct of the owner.
Actions; Intervention; A court which has no jurisdiction over the principal action has no jurisdiction over a
complaint-in-intervention—intervention presupposes the pendency of a suit in a court of competent
jurisdiction.—The RTC cannot be faulted for dismissing petitioner’s complaint-in-intervention. Considering that it had no
jurisdiction over respondents’ action and over the shipment subject of the complaint, all proceedings before it would be
void. The RTC had no jurisdiction to take cognizance of the complaint-in-intervention and act thereon except to dismiss
the same. Moreover, considering that intervention is merely ancillary and supplemental to the existing litigation and
never an independent action, the dismissal of the principal action necessarily results in the dismissal of the
complaint-in-intervention. Likewise, a court which has no jurisdiction over the principal action has no jurisdiction over a
complaint-in-intervention. Intervention presupposes the pendency of a suit in a court of competent jurisdiction.
Jurisdiction of intervention is governed by jurisdiction of the main action.

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Asian Terminals, Inc. vs. Bautista-Ricafort, 505 SCRA 748, G.R. No.

166901 October 27, 2006

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