Introduction to Law Whether or not CFI erred in affirming

Topic: Effectivity of Laws Collector of Customs’ interpretation of Article

117, particularly paragraphs c and g, of the
Relevant Doctrine: Art. 2 of the Civil Code Tariff Law
Laws shall take effect after 15 days following the Ruling/s:
completion of their publication in the Official Gazette
or in a newspaper of general circulation in the  NO, CFI did not err in affirming the
Philippines unless it is otherwise provided. respondent’s interpretation
 The Court applied the Doctrine of Stare
Virgilio Garcillano v House of Representatives Decisis, to quote:
G.R. No. 170338, December 23, 2008 o It is a rule well established in the
Ponente: Justice Nachura interpretation of customs laws that,
where there has been a long
acquiescence in a regulation by
Facts: which the rights of parties for years
have been determined and
 The petitioners imported into the Philippine adjusted, such interpretation
Islands certain cotton goods. should be followed in the absence
 Upon which the respondent imposed a duty of the most cogent and persuasive
in accordance with Article 117(c) of Tariff reasons to the contrary.
Laws applicable in the Philippines and a
surtax of 30% per annum was also imposed Therefore, the Court, speaking thru Justice Johnson,
in addition to the former based on Article affirmed the decision of CFI with costs.
17(g) of the same statute.
 Art 117(c) and (g) of the tariff law applicable
in the Philippines provides as follows:
o "Textiles, plain and without figures,
not stamped or printed, whatever
be their width, weighing eight kilos
or more per one hundred square
meters, having—
 (c) From thirty-two to
thirty-four threads, N. W.,
kilo, eighteen cents…
 (g) The same textiles,
stamped, printed, or
manufactured with the
dyed yarns, dutiable as
the textile, with a surtax of
thirty per centum.
 Against this ruling, they filed a protest.
 The respondent argued that Art 117(g)
clearly refers to all description of textiles
preceding it.
 Further, Collector of Customs held that the
interpretation was followed since 1901 and
the law has been amended twice, without the
legislature having made any change in that
portion of the Article.
 The CFI affirmed the ruling of Collector of
Customs re Article 117 of Tariff Law, which
is in favor of the respondent.
Hence, this Petition.
Issue: