DE LEON, M.S.

STATUTORY CONSTRUCTION

Case Title: Republic Flour Mills v. Commissioner of Customs

Case Reference: GR No. 28463
Promulgation Date: May 31, 1971
Ponente: Fernando, J.
Topic:

Facts

This case involves a dispute between Republic Flour Mills, Inc. and the Commissioner of
Customs regarding the interpretation of the term “products of the Philippines” in Section
2902 of the Tariff and Customs Code.

The petitioner contends that bran and pollard, which are byproducts of the milling process
used in flour production, should be categorized as waste and not as products of the
Philippines. On the contrary, the Commissioner of Customs argues that the petitioner is
accountable for wharfage dues on the exportation of bran and pollard.

The Court of Tax Appeals sided with the Commissioner's decision, prompting the petitioner
to appeal the case to the Supreme Court for further review and resolution.

Issue
Whether or not the respondent is liable fo wharfage dues on its exportation of bran and
pollard as they are not “products of the Philippines”

Ruling
Yes. The language of Section 2802 is unambiguous.

"There shall be levied, collected and paid on all articles imported or brought into the
Philippines, and on products of the Philippines ... exported from the Philippines, a charge of
two pesos per gross metric ton as a fee for wharfage ...."

It clearly outlines that charges for wharfage fees apply to both articles imported into the
Philippines and products of the Philippines exported from the country. This distinction covers
goods produced within the nation's borders. The language used makes it evident that
domestically produced items are encompassed within the scope of this section.

The Court emphasizes the importance of applying the law as written and interpreting it in a
manner that is consistent withits plain meaning and legislative intent. It also highlights the
need to avoid undue restriction of the coverage of the law and to respect the clear legislative
mandate.