Jul 18, 2012

Yaokasin v Commissioner Digest


GR No. 84111, December 22, 1989

Facts: The Philippine Coast Guard seized 9000 sacks of refined sugar owned by petitioner Yaokasin, which were then being unloaded from the M/V Tacloban, and turned them over to the custody of the Bureau of Customs. On June 7, 1988, the District Collector of Customs ordered the release of the cargo to the petitioner but this order was subsequently reversed on June 15, 1988. The reversal was by virtue ofCustoms Memorandum Order (CMO) 20-87 in implementation of the Integrated Reorganization Plan under P.D. 1, which provides that in protest and seizure cases where the decision is adverse to the government, the Commissioner of Customs has the power of automatic review.
Petitioner objected to the enforcement of Sec. 12 of the Plan and CMO 20-87 contending that these were not published in the Official Gazette. The Plan which was part of P.D. 1 was however published in the Official Gazette.

Issue: W/n circular orders such as CMO 20-87 need to be published in the OG to take effect

NO.
Article 2 of the Civil Code does not apply to circulars like CMO 20-87 which is an administrative order of the Commissioner of Customs addressed to his subordinates, the custom collectors. Said issuance requiring collectors of customs to comply strictly with Section 12 of he Plan, is addressed only to particular persons or a class of persons (the customs collectors), hence no general applicability. As held in Tanada v. Tuvera, “It need not be published, on the assumption that it has been circularized to all concerned.”

Moreover, Commonwealth Act. 638 provides an enumeration of what shall be published in the Official Gazette. It provides that besides legislative acts, resolutions of public nature of Congress, executive, administrative orders and proclamations shall be published except when these have no general applicability.



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