Commissioner of Customs v. Relunia G.R. No. L-11860. May 29, 1959

Facts: RPS  Misamis Oriental, a unit of the Philippine Navy, was dispatched to Japan to transport contingents bound for Puson, Korea, and carry Christmas gifts for our soldiers there. It was used for transportation purposes and it made trips between Korea and Japan. While RPS Misamis Oriental was in Japan, it loaded 180 cases containing various articles which are subject to customs duties. Upon arrival in the Philippines, these articles were forfeited because of violations of Customs Law. Commissioner of Customs argued that RPS Misamis Oriental is subject to Administrative Code Sec. 1363 which says that unmanifested merchandise found in the vessel shall be forfeited.

Issue: Are Navy vessels, like RPS Misamis Oriental, required to have a manifest?

Held: Yes.

Ratio: Even if Sec. 1221 of the Administrative Code is entitled “Entrance of Vessels in Foreign Trade,” Sec. 1228 states that it is required that “every vessel from a foreign port or place must have on board complete written or typewritten manifests of all her cargoes. Also, RPS Misamis Oriental claimed to have submitted one to a certain Mr. Ysla, but was denied by the latter.

StatCon maxim: The title can be resorted to as an aid where there is doubt as to the meaning of the law or as to the intention of the legislature in enacting it, and not otherwise.