GR L 12330; (January, 1917) (Digest)
G.R. No.: L-12330
Title: Ynchausti & Co. vs. John S. Stanley, Collector of Customs of the Philippine Islands
FACTS:
Ynchausti & Co. filed a petition for prohibition under the Code of Civil Procedure against the Insular Collector of Customs. The Collector had ordered the company’s coastwise vessels to carry a third mate as an officer. Ynchausti & Co. contended that this order was illegal and in excess of the Collector’s authority because the governing law, Act No. 2614 (amending Act No. 2507), specifically required for steam vessels of 500 to 1,500 gross tons only a master, a first mate, and a second mate. The Collector defended his order based on Section 1312(e) of the newly enacted Administrative Code (Act No. 2657), which granted the Bureau of Customs the power to fix the number and classes of marine officers on Philippine vessels. The core conflict was whether this general grant of authority in the Administrative Code repealed or overrode the specific provisions of Act No. 2614 .
ISSUE:
Did Section 1312(e) of the Administrative Code (Act No. 2657), granting the Collector of Customs the authority to fix the number and classes of marine officers, repeal the specific requirements set forth in Act No. 2614 , thereby allowing the Collector to mandate a third mate?
RULING:
No. The Supreme Court ruled in favor of Ynchausti & Co. The specific provisions of Act No. 2614 were not repealed by the general authority granted to the Collector of Customs in the Administrative Code. The Court held that:
1. There was no express repeal of Act No. 2614 or Act No. 2507 in the Administrative Code’s schedules of repealed acts.
2. There was no necessary conflict between the two laws. Act No. 2614 specifically fixed the number of officers required, while Section 1312(e) of the Administrative Code conferred a general administrative authority to enforce such laws. The Collector’s power was to administer and fix the number in accordance with existing law, not to create new requirements contrary to it.
3. The legislative intent supported this interpretation. Act No. 2614 was passed on February 4, 1916, and the Administrative Code on February 24, 1916. It was improbable that the Legislature intended to repeal a detailed, recently enacted statute within three weeks. Furthermore, subsequent legislation (Act No. 2662) extended Act No. 2614 , confirming the Legislature’s understanding that it remained in force.
4. The Collector’s role under the Administrative Code was to determine facts (like a vessel’s tonnage) and then apply the specific statutory requirements, not to impose additional ones.
Therefore, the Collector of Customs acted in excess of his jurisdiction by ordering a third mate, and the demurrer was overruled.
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