23 Provident Tree vs. Batario (1)

Topic: Doctrine of Primary Jurisdiction Provident Tree Farms, INC. (PTFI) vs Hon. Batario & AJ InternationL Corp. (AJIC) GR 92285 March 28, 1994 DOCTRINE: Cases before the BOC must be fully fleshed out before it prior to elevating the issues to a regular court in keeping with the exhaustion of administrative remedies. (primary jurisdiction) FACTS: 

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PTFI is a Phil corporation engaged engaged in industrial tree planting. It supplies to a local match manufacturer solely for production of matches. There’s a state policy policy to encourage qualified persons to engage in industrial tree plantation under Revised Forestry Code which provides a set of incentives to corporations like PTFI and is a qualified ban against importation of wood. Respondent, AJIC, imported imported matches from Indonesia Indonesia which the BOC released which violates the Revised Revised Forestry Forestry Code’s ban of importing wood and wood-derivated wood -derivated products.

RTC: 

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PTFI filed with the RTC of Manila Manila a complaint for injunction and and damages with with prayer for for a TRO TRO against Commissioner of Customs to prohibit the latter from importing matches. AJIC moved to dismiss the complaint alleging that: The Commissioner Commissioner of Customs and and not the regular regular court has exclusive jurisdiction to determine the legality legality o of an importation. The release of importations had rendered rendered injunction moot and academic. o The prayer for damages has no basis as the Commissioner’s acts are in accordance with law. o o The complaint for injunction cannot cannot stand it being only a provisional relief and not not a principal remedy. remedy. PTFI opposed the motion to dismiss.  AJIC’s motion to dismiss was denied. AJIC filed a motion motion for reconsideration and the Court reconsidered reconsidered and and dismissed the case on the the ground ground that it had no jurisdiction to determine what are legal or illegal importations. importations . PTFI seeks to set aside aside the order order of respondent court court and prays prays for the continuation of the hearing of the case contending that what was brought before the trial court was a civil case for injunction for the purpose of securing compliance with the provision of the RFC.

ISSUE: Whether or not the Bureau of Customs holds jurisdiction in the matter of wood product importation. HELD: The only subject of this incentive is a ban against importation of wood and wood products which is to be enforced by Bureau of Customs since it has under the Tariff and Customs Code the exclusive original jurisdiction over seizure and forfeiture cases. To allow the regular court to direct the Commissioner is clearly an interference with the exclusive jurisdiction of the BOC. PTFI’c correspondence correspondence with the BOC contesting the legality of match importations may already take the nature of administrative proceedings the pendency of which would preclude the court from interfering with it under the doctrine of primary jurisdiction. In Presidential Commission on Good Government v. Peña, Peña,

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 the court held that —

. . . . under the "sense-making and expeditious doctrine of primary  jurisdiction . . . . . the courts cannot or will not determine a controversy involving a question which is within the jurisdiction of an administrative tribunal, where the question demands the exercise of sound administrative discretion requiring the special knowledge, experience, and services of the administrative tribunal to determine technical and intricate matters of fact, and a uniformity of ruling is essential to comply with the purposes of the regulatory statute administered ( Pambujan Sur United Mine Workers v. Samar Mining Co., Inc., Inc., 94 Phil. 932, 941 [1954].) In this era of clogged court dockets, the need for specialized adminis trative boards or commissions with the special knowledge, experience and capability to hear and determine promptly disputes on technical matters or essentially factual matters, subject to judicial review in case of grave abuse of discretion, has become well indispensable . . . . The court cannot compel an agency to do a particular act or to enjoin such act which is within i ts prerogative, except when in the exercise of its authority it gravely abuses or exceeds its jurisdiction. In the case at bench, we have no occasion to rule on the issue of grave abuse of discretion or excess of jurisdiction as it is not before us. Thus, the order of the RTC was affirmed and the petition for review was denied.