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    PTFI vs. Batario

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    Jhoel Villafuerte
    PTFI filed a complaint against AJIC and the Commissioner of Customs to enjoin AJIC from importing matches and wood products. The lower court ruled it had no jurisdiction over importation legality. The Supreme Court ruled that [1] the Bureau of Customs has exclusive jurisdiction over importation bans and seizure/forfeiture cases according to the Tariff and Customs Code, [2] courts cannot determine controversies that fall under an administrative tribunal's jurisdiction when special expertise is required, and [3] PTFI's correspondence with the Bureau of Customs over import legality had already initiated an administrative proceeding.

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    PTFI vs. Batario

    Uploaded by

    Jhoel Villafuerte
    99 views1 page
    PTFI filed a complaint against AJIC and the Commissioner of Customs to enjoin AJIC from importing matches and wood products. The lower court ruled it had no jurisdiction over importation legality. The Supreme Court ruled that [1] the Bureau of Customs has exclusive jurisdiction over importation bans and seizure/forfeiture cases according to the Tariff and Customs Code, [2] courts cannot determine controversies that fall under an administrative tribunal's jurisdiction when special expertise is required, and [3] PTFI's correspondence with the Bureau of Customs over import legality had already initiated an administrative proceeding.

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    PTFI filed a complaint against AJIC and the Commissioner of Customs to enjoin AJIC from importing matches and wood products. The lower court ruled it had no jurisdiction over importation legality. The Supreme Court ruled that [1] the Bureau of Customs has exclusive jurisdiction over importation bans and seizure/forfeiture cases according to the Tariff and Customs Code, [2] courts cannot determine controversies that fall under an administrative tribunal's jurisdiction when special expertise is required, and [3] PTFI's correspondence with the Bureau of Customs over import legality had already initiated an administrative proceeding.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    99 views1 page

    PTFI vs. Batario

    Uploaded by

    Jhoel Villafuerte
    PTFI filed a complaint against AJIC and the Commissioner of Customs to enjoin AJIC from importing matches and wood products. The lower court ruled it had no jurisdiction over importation legality. The Supreme Court ruled that [1] the Bureau of Customs has exclusive jurisdiction over importation bans and seizure/forfeiture cases according to the Tariff and Customs Code, [2] courts cannot determine controversies that fall under an administrative tribunal's jurisdiction when special expertise is required, and [3] PTFI's correspondence with the Bureau of Customs over import legality had already initiated an administrative proceeding.

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    PROVIDENT TREE FARMS, INC. (PTFI) vs. Hon.

    BATARIO and AJ International Corp (AJIC)

    FACTS: Petitioner PTFI is a Philippine corporation engaged in industrial tree planting. It grows gubas trees in its
    plantations which it supplies to a local match manufacturer solely for production of matches. In consonance with the
    state policy to encourage qualified persons to engage in industrial tree plantation, Sec. 36, par. (1), of the Revised
    Forestry Code confers on entities like PTFI a set of incentives among which is a qualified ban against importation of
    wood and "wood-derivated" products.

    On 5 April 1989, private respondent A. J. International Corporation (AJIC) imported 4 containers of matches from
    Indonesia and 2 or more containers of matches from Singapore. On 25 April 1989, upon request of PTFI, Secretary
    Factoran of the DENR issued a certification that "there are enough available softwood supply in the Philippines for the
    match industry at reasonable price." In light of this, PTFI filed with the RTC of Manila a complaint for injunction and
    damages with prayer for a TRO against respondents Commissioner of Customs and AJIC to enjoin the latter from
    importing matches and "wood-derivated" products, and the Collector of Customs from allowing and releasing the
    importations. The case was raffled to respondent Judge Demetrio M. Batario. Lower court ruled in favor of respondents,
    stating that it had "no jurisdiction to determine what are legal or illegal importations."

    ISSUE: Whether or not BOC holds jurisdiction in matter of wood product importation.

    RULING: YES. The enforcement of the importation ban under Sec. 36, par. (l), of the Revised Forestry Code is within
    the exclusive realm of the Bureau of Customs, and direct recourse of petitioner to the Regional Trial Court to compel
    the Commissioner of Customs to enforce the ban is devoid of any legal basis. An order of a judge to impound, seize or
    forfeit must inevitably be based on his determination and declaration of the invalidity of the importation, hence, an
    usurpation of the prerogative and an encroachment on the jurisdiction of the Bureau of Customs.

    Petitioner anchors his complaint on a statutory privilege or incentive granted under Sec. 36, par. (l), of the
    Revised Forestry Code. The only subject of this incentive is a ban against importation of wood, wood products or wood-
    derivated products which is to be enforced by the Bureau of Customs since it has, under the Tariff and Customs Code,
    the exclusive original jurisdiction over seizure and forfeiture cases 13 and, in fact, it is the duty of the Collector of
    Customs to exercise jurisdiction over prohibited importations.

    The courts cannot or will not determine a controversy involving a question which is within the jurisdiction of an
    administrative tribunal, where the question demands the exercise of sound administrative discretion requiring the
    special knowledge, experience, and services of the administrative tribunal to determine technical and intricate matters
    of fact, and a uniformity of ruling is essential to comply with the purposes of the regulatory statute administered.

    Also, PTFI's correspondence with the Bureau of Customs contesting the legality of match importations may
    already take the nature of an administrative proceeding the pendency of which would preclude the court from interfering
    with it under the doctrine of primary jurisdiction.

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