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1 STATCON G03 | ATTY.

NOGRALES CADIZ | CAMINADE | CORDOVEZ | CUNANAN | FERRARIS | KO| OCAMPO | TAN |YU

Lopez Sons vs Court of Tax Appeals If taken literally, a person affected by a decision of the
GR No. L-9274 Collector of Customs may appeal to the Court of Tax Appeals. And
Feb. 1, 1957 since no mention is made about the decision of the Commissioner of
Topic: Legislative Intent Customs, a person affected by said decision may not appeal to the
Court of Tax Appeals. In other words, the provision conferring
Facts: appellate jurisdiction on the CTA to review decisions of the
Petitioner, Rufino Lopez & Sons, is appealing the resolution of the Commissioner of Customs (Sec. 7) would be empty, meaningless and
Court of Tax Appeals for dismissing its appeal from a decision of the unenforceable because under Sec. 11, no person affected by the
Collector of Customs for the Port of Manila. decision of the Commissioner of Customs may appeal to the CTA.
The SC, together with the Tax Court and Solicitor
 Petitioner imported hexagonal wire netting from Germany. General, then said that a clerical error was committed in Sec.
 The Manila Collector of Customs assessed the corresponding 11, as Sec. 11 was meant to further complement Sec. 7. And that
customs duties to which petitioners paid said amount. it would be more reasonable and logical to hold that in Sec. 11
 Subsequently, the Collector reassessed the dollar value of the of RA 1125, the Legislature meant and intended to say
cost and freight and as a result, an additional amount of Commissioner of Customs and not Collector of Customs.
P1,966.59 was levied and imposed upon petitioner. They further said that if they follow the literal meaning and
 Because the petitioner failed to secure a reconsideration of the wording of Sec. 11, then the supervision and control of the
reassessment and levy of the additional customs duties, Commissioner of Customs over his Collector of Customs, and his
petitioner appealed to the Court of Tax Appeals. right to review their decisions, would not only be gravely effected,
 Court of Tax Appeals dismissed the appeal on the ground that it but even destroyed. The court believes that such was not the
had no jurisdiction to review the decisions of the Collector of intention of the Legislature in passing RA. 1125.
Customs of Manila, citing Sec. 7 of RA 1125. Likewise, SC contends that they are not exactly indulging in
 Petitioner then filed present case seeking for reversal of said judicial legislation but merely endeavoring to rectify and correct a
resolution of dismissal, invoking Sec. 11 of RA 1125. clearly clerical error in the wording of a statute, in order to give due
course and carry out the evident intention of the Legislature.
Issue: Under the rules of Statcon, it is not the letter but rather
WON the Court of Tax Appeals has jurisdiction to review the spirit of the law and intention of the Legislature that is
the decisions of the Collector of Customs of Manila important. When the interpretation based on its exact and
literal import of words would lead to absurd or mischievous
Held: results, or would contravene the clear purposes of the
NO. Legislature, it should be construed according to its spirit and
Sec. 7 of the RA 1125 specifically provides that the Court of reason, disregarding the letter of the law.
Tax Appeals has appellate jurisdiction to review the decisions of the Court rules that under RA 1125 and the Customs Law, the
Commissioner of Customs. On the other hand, Sec. 11, which Court of Tax Appeals has no jurisdiction to review the decisions of
enumerates the persons and entities who may appeal (those the Collector of Customs.
affected by a decision or ruling of the Collector of Customs), fails to Appealed order of dismissal is affirmed. Costs against
mention the Commissioner of Customs. There is then a clear petitioner.
discrepancy between the two.