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ASIAN TERMINALS v. HELEN BAUTISTA-RICAFORT

FACTS:

This case involves a dispute over the possession and ownership of vehicles imported by the plaintiffs, who are duly-licensed importers. The vehicles were impounded by the District Collector of Customs and stored at the warehouse of Asian Terminals, Inc. (ATI). The importers filed a complaint against the Secretary of Finance, Customs Commissioner, and the Chief Executive of the Societe Generale de Surillee, seeking the release of their vehicles.

The importers argued that the importation of right-hand drive vehicles is not prohibited under RA No. 8506, as long as conversion kits are included. They claimed to have paid the required taxes, dues, and charges amounting to P7,528,635.00 to the government. The plaintiffs were granted a writ of replevin by the RTC, and with the assistance of the PNP Director, the vehicles were transferred to the RTC.

The defendants, however, filed an Omnibus Motion seeking reconsideration of the RTC's order granting the writ of replevin. They argued that the Bureau of Customs has exclusive jurisdiction over the vehicles and opposed the release of the vehicles to the importers.

On the other hand, ATI filed a Third-Party Claim alleging a lien over the vehicles for storage and other charges amounting to P13,820,150.93. ATI sought to keep the vehicles in their possession until their dues were paid.

The court initially dismissed the importers' complaint, citing grounds including lack of jurisdiction. However, the OSG filed a motion for reconsideration, requesting the court to determine who is entitled to possess the vehicles. ATI, for their part, filed a motion for clarification, insisting on the admission of their Complaint-in-Intervention.

ISSUES:

  1. Whether or not the lower court committed grave abuse of discretion when it outrightly dismissed the subject complaint filed by private respondents.

  2. Whether or not the lower court committed grave abuse of discretion when it denied the motion for reconsideration filed by the petitioner.

  3. Whether or not the public respondents committed grave abuse of discretion when it outrightly dismissed the complaint-in-intervention filed by the petitioner.

  4. Whether the consent of the petitioner as intervenor is necessary for the dismissal of the main action.

  5. Whether the third-party complaint may still be maintained even if the lower court has no jurisdiction over the principal action.

  6. Whether the Court of Appeals erred in dismissing the petition for certiorari of the petitioner.

  7. Whether or not the RTC had jurisdiction over the action for replevin and the vehicles subject matter thereof.

  8. Whether or not the initial orders of the RTC granting the issuance of the writ of replevin and its implementation are void.

  9. Whether or not the Court of Appeals decision affirming the dismissal of the petition is correct.

RULING:

  1. The Court of Appeals (CA) ruled that the Regional Trial Court (RTC) had no jurisdiction over the complaint filed by the private respondents. The Collector of Customs sitting in seizure and forfeiture proceedings has exclusive jurisdiction to hear and determine all questions relating to the seizure and forfeiture of dutiable goods. The RTC had no review powers over such proceedings. Since the RTC had no jurisdiction over the main case, it was also bereft of authority to hear the third-party claim or the complaint-in-intervention filed by the petitioner. The CA dismissed the petition for lack of merit.

  2. The CA found no grave abuse of discretion on the part of the lower court in denying the motion for reconsideration filed by the petitioner.

  3. The CA ruled that the dismissal of the main action also resulted in the dismissal of the complaint-in-intervention filed by the petitioner. Intervention is an ancillary and supplemental proceeding that is subordinate to the main proceeding unless otherwise provided by statute or the Rules of Court. Since the RTC had dismissed the main action, there was no more principal proceeding in which the petitioner could intervene.

  4. The consent of the petitioner as intervenor is not necessary for the dismissal of the main action.

  5. The third-party complaint cannot be maintained if the lower court has no jurisdiction over the principal action.

  6. The Court of Appeals did not err in dismissing the petition for certiorari.

  7. The RTC did not have jurisdiction over the action for replevin and the vehicles subject matter thereof. 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. Since the RTC acted without jurisdiction, its actions are considered void.

  8. The initial orders of the RTC granting the issuance of the writ of replevin and its implementation are void. The District Collector of Customs allowed the release of the vehicles and their transfer to the custody of the RTC, but it did not lose jurisdiction over the vehicles and it did not vest jurisdiction on the RTC to take cognizance of and assume jurisdiction over the petition for replevin. The transfer of custody to the RTC was done to ensure the implementation of the writ, not to grant jurisdiction to the RTC.

  9. The Court of Appeals decision affirming the dismissal of the petition is correct. The RTC had no jurisdiction over the action and the vehicles subject of the complaint, thus all proceedings before it would be void. The dismissal of the principal action, therefore, results in the dismissal of the complaint-in-intervention. Intervention presupposes the pendency of a suit in a court of competent jurisdiction.

PRINCIPLES:

  • The Court of Tax Appeals exercises exclusive appellate jurisdiction to review the ruling of the Commissioner in seizure and confiscation cases to the exclusion of the Court of First Instance (now Regional Trial Court) which may not interfere with the Commissioner's decisions.

  • The Collector of Customs sitting in seizure and forfeiture proceedings has exclusive jurisdiction to hear and determine all questions relating to the seizure and forfeiture of dutiable goods.

  • Intervention is an ancillary and supplemental proceeding that is subordinate to the main proceeding unless otherwise provided by statute or the Rules of Court.

  • The Bureau of Customs has exclusive jurisdiction over seized and forfeited goods.

  • Regional Trial Courts do not have jurisdiction over seizure and forfeiture proceedings conducted by the Bureau of Customs.

  • The proper fora for review in seizure and forfeiture cases are the Commissioner of Customs, the Court of Tax Appeals, and the Court of Appeals.

  • 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 and entails a determination of the legality of their importation.

  • The release of the vehicles and their transfer to the custody of the RTC does not vest jurisdiction on the RTC to take cognizance of and assume jurisdiction over the action for replevin.

  • Intervention is ancillary and supplemental to the existing litigation and is never an independent action. The jurisdiction of intervention is governed by the jurisdiction of the main action.