Statutory Construction- Commissioner vs. Relunia

STATUTORY CONSTRUCTION- THE ISSUE WITH REGARD TO THE USE OF THE TITLE OF STATUTE TO MAKE INTERPRETATION EASIER


Case of Commissioner vs. Relunia
No. 11860 29May1959

FACTS OF THE CASE:

On December 10 1953, the RPS “MISAMIS ORIENTAL” a unit of the Philippine Navy was dispatched to Japan to transport contingents of the 14th BCT bound for Pusan Korea and carry Christmas gifts for our troops there. It seems thereafter, it was used for transportation purposes in connection with the needs of Filipino Soldiers in Korea.

While in Japan it loaded 180 cases containing various articles subject to custom duties. Upon arrival in the Philippines all theses articles were then declared forfeit by the Collector of Customs of Manila for violations of the customs law.

ISSUES OF THE CASE:

Is the RPS MISAMIS ORIENTAL being a Navy vessel required to have a manifest?

Yes, Because although the law prescribes that only vessels engaged in foreign trade are required to present a manifest, the interpretation of the court all vessels whether private or government owned including ships of the Philippine Navy, coming from a foreign port with the possible exception of war vessels or vessels employed by any foreign government not engaged in the transportation of merchandise by way of trade, as provided for in the 2nd paragraph of sec. 1221 of the Revised Administrative Code, are required to prepare and present a manifest to the customs authorities upon arrival at any Philippine Port.

HELD:
APPEALED DECISION OF THE COURT OF TAX APPEALS AS REGARDS TO THE FORFEITURE OF THE ELECTRIC RANGE IN QUESTION IS SET ASIDE, AND THE DECISION OF THE COMMISSIONER OF CUSTOMS AFFIRMING THAT OF THE COLLECTOR OF CUSTOMS AS REGARDS TO THE SAME ARTICLE IS AFFIRMED.

STAT CON LESSON:

The title of the statute can be resorted to if there is doubt as to the legislative intent. (The title can be resorted to as an aid where there is doubt as to the meaning of the law or the intention of the legislature, and not otherwise.)

I hope this helps.

Jeff David