Rufino Lopez v.

Court of Tax Appeals

Thesis Statement:
Petition for Review on certiorari the decision of the Court of Tax Appeals

Ponente:
Montemayor, J.

Facts:
1. The Petitioner imported Netting Materials from Hamburg, Germany.
2. He Already Paid the necessary customs and duties assessed by the Collector of Customs and the
Shipments were Released.
3. The Collector of Customs reassessed the Dollar Value and imposed another P1,966.59 to the
Petitioner.
4. The Petitioner Appeals to the Court of Tax Appeals but the Latter denied the petition on the ground
that the Court of Tax Appeals has no Jurisdiction to review decisions of the Collector Customs of
Manila in Accordance to Sec. 7 of Republic Act No. 1125

Issue:
Whether or not the Court of Tax Appeals has Jurisdiction to review decisions of Collector Customs in
accordance with Section 11 of Republic Act No. 1125

Ruling:
No, The Court of Tax Appeals has no Jurisdiction to review on matters containing appeal to the
decisions of Collector of Customs.

Under the rule of Statutory Construction, it is not the letter but rather the spirit of the law and
intention of the Legislature that is important and which matters.

The case at bar is a mere clerical and misprint error on the provision of Sec 11 of Republic Act 1125 in
particular to the “Collector of Customs” instead of “Commisioner of Customs”, wherein, it is a clear
oversight on the intention of the Law maker to give Court of Tax Appeals a Jurisdiction concerning the
appeals on decision of the Commissioner of Customs.

Hence, the appeal was dismissed and the Court ruled that the Respondent Court has no Jurisdiction
over the Collector of Customs.