Provident Tree Farms, Inc. v. Hon. Demetrio Batario G.R. No.

92285, March 28, 1994, 231 SCRA 463

Syllabus: The enforcement of the importation ban under Section 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. To allow the regular court to direct the Commissioner to impound the imported matches, as
petitioner would, is clearly an interference with the exclusive jurisdiction of the Bureau of Customs over
seizure and forfeiture cases. 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, a usurpation of the
prerogative and an encroachment on the jurisdiction of the Bureau of Customs. In other words, the
reliefs directed against the Bureau of Customs as well as the prayer for injunction against importation of
matches by private respondent A.J. International Corporation (AJIC) may not be granted without the
court arrogating upon itself the exclusive jurisdiction of the Bureau of Customs.

FACTS:

In spite of the importation restriction, A.J. International Corporation (AJIC) imported matches from other
nations.

As a result, PTFI filed a case for injunctive and damages, as well as a request for a temporary restraining
order, against by the Commissioner of Customs and AJIC, seeking an injunction prohibiting the other
from undertaking the banned importations.

The AJIC filed a suit to disqualify, claiming that Commissioner of Customs, not really the ordinary court,
has "exclusive competence to judge the legitimacy of an importing or verify if the requirements defined
by law for an importation...xxx." The motion was first refused, but it was later reinstated.

If the trial court has jurisdiction over the matter at hand.

ISSUE:

If the trial court has jurisdiction over the matter at hand.

RULING:

No. That trial court lacks standing.

Because the incentive entails a prohibition upon this importation of wood, wood products, or wood
derived products, it'll be imposed by the Bureau of Customs, that also has the exclusive as well as
innovative judicial power over seizure and forfeiture cases. "[Particular main result, it is also the
Collector of Customs' duty to exert power over banned importations."

Enabling a ordinary jurisdiction to instruct the Commissioner to detain the imported matches, as
petitioner proposes, manifestly interferes with the Bureau of Customs' exclusive authority over
confiscation and forfeiture proceedings. A judge's ruling to detain, confiscate, or forfeiture must
unavoidably be founded on his decision and proclamation of the illegality of the importation,
constituting a violation of the jurisdiction as well as an intrusion on the Bureau of Customs' authority. In
other terms, the provisions aimed against by the Bureau of Customs, and the private respondent AJIC's
demand for such a prohibition against by the importing of matches, cannot be issued alone without
court abdicating its jurisdiction.
 Although no process for enforcing the import restriction is specified, the Bureau of Customs
retains control over particular topic. The lack of a statutory process does not preclude the
implementation of legal provisions.