G.R. No. L-33146 May 31, 1977
THE COMMISSIONER OF CUSTOMS and THE COLLECTOR OF CUSTOMS, petitioners, vs. HON. PEDRO C. NAVARRO, Judge of the Court of First Instance of Rizal, Branch II, and JUANITO S. FLORES, doing business under the name and style of JS. F. ENTERPRISES and ASIATIC INCORPORATED, represented by EUGENIO VILLANUEVA, respondents.

FACTS

The Collector of Customs initiated forfeiture proceedings against 1,350 cartons of fresh fruits imported by private respondent Juanito S. Flores, doing business as JS.F. Enterprises and Asiatic Incorporated. The goods were classified as non-essential consumer commodities banned under Central Bank Circulars Nos. 289, 294, and 295, rendering them prohibited importations subject to seizure and forfeiture under the Tariff and Customs Code. While these administrative proceedings were pending, the private respondents filed a civil case with the Court of First Instance of Rizal, Branch II, presided by Judge Pedro C. Navarro, seeking to restrain the customs authorities from proceeding with an auction sale of the perishable goods.
Respondent Judge Navarro issued an order dated January 4, 1971, granting a writ of preliminary injunction against the petitioners, thereby restraining the auction. The Commissioner and Collector of Customs then filed this petition for certiorari before the Supreme Court, asserting that the lower court acted without jurisdiction. They argued that seizure and forfeiture cases fall within the exclusive domain of customs authorities. Upon being required by the Supreme Court to file an answer, the private respondents submitted a manifestation instead, stating they had decided to abandon their interest in the case, ostensibly to avoid further expense as the shipments had deteriorated, and submitted the case based on the pleadings.

ISSUE

Whether or not the Court of First Instance has jurisdiction to issue a writ of preliminary injunction restraining customs forfeiture proceedings, which are pending before the Bureau of Customs.

RULING

The Supreme Court ruled that the Court of First Instance acted without jurisdiction. The writ of certiorari was granted, the challenged order was nullified, and the lower court was ordered to dismiss the civil case. The legal logic is firmly anchored on the doctrine of primary jurisdiction and the exclusive competence of customs authorities over seizure and forfeiture proceedings. The Court emphasized that the question of seizure and forfeiture is for the Collector of Customs to determine in the first instance, with an appeal lying to the Commissioner of Customs, then to the Court of Tax Appeals. Regular courts of first instance are devoid of competence to interfere with or assume cognizance over such matters.
This exclusive jurisdiction of the Bureau of Customs is a settled doctrine, reiterated in a long line of cases including Pascual v. Commissioner of Customs, Pacis v. Averia, and Papa v. Mago. The Court explained that allowing a court of first instance to exercise jurisdiction over an action concerning property subject to customs forfeiture proceedings would encroach upon and render futile the jurisdiction of the Collector of Customs. The customs bureau acquires exclusive jurisdiction over imported goods for enforcing customs laws from the moment the goods are in its possession or control. Consequently, the respondent judge’s issuance of the injunction was a grave abuse of discretion amounting to lack of jurisdiction. The Supreme Court made permanent its own preliminary injunction against the enforcement of the lower court’s order.