ARTICLE III SECTION 1 CASE # 18
Degree of proof required is merely substantial evidence
Feeder International Line LTD. Vs CA
DOCTRINE:
FACTS:
1. A foreign vessel operated by Feeder International Shipping Lines of
Singapore was carrying 1,100 metric tons of gas oil and 1,000 metric
tons of fuel oil consigned to Far East Synergy Corp. of Zamboanga.
a. However, the vessel anchored in Iloilo without informing
Iloilo authorities.
b. The vessel did not have the required documents except a
clearance from Singapore clearing the vessel for Zamboanga.
c. The vessel was held and a warrant seize the fuel oil cargo was
issued for violating the Tariff and Customs code of the
Philippines.
2. Feeder International filed a petition claiming:
a. There was only circumstantial evidence that illegal
importation was committed.
b. Petitioner was deprived of property without due process
and has the right to be presumed innocent since the decision
was not supported by proof beyond reasonable doubt.
c. The sworn statements of Deposa and Torres were taken
without assistance of counsel.
ISSUES: WON the contentions of Feeder International amount to a violation
to their right to due process. NO.
RULING:
1. Seizure and forfeiture proceedings under tariff and customs laws is
not criminal in nature. No need for proof beyond reasonable doubt to
seize property.
a. These don’t result in conviction of offender so are purely civil
and administrative.
b. The penalty in seizure cases is distinct and separate from
criminal cases. Here, unlawful goods are merely seized.
c. Since it is not a criminal proceeding, proof beyond reasonable
doubt is not required.
d.
which means such relevant evidence as reasonable mind
might accept as adequate to support a conclusion.
e. A corporate entity like Feeder International has no
personality to invoke the right to be presumed innocent since
this is only available to individuals accused in a criminal case.
2. Petitioner is guilty of illegal importation because:
a. Their vessel did not notify the Iloilo port or customs
authorities of its arrival.
b. Their vessel did not have the required documents. It only has
a document clearing the vessel for Zamboanga.
3. The fact that the testimonies of Deposa and Torress were given
without the assistance of counsel does not violate their constitutional
right to be assisted by counsel.
a. The right to the assistance of counsel is not indispensable to
due process unless required by constitution or law.
b. Exception is made only during custodial investigation when
a person is suspected of a crime.
c. Nothing in constitution that says a party in a non-criminal
proceeding is entitled to be represented by counsel and
without this, he will not be bound by such proceedings.
d. There is no compelling reason to doubt the validity of their
sworn statements.
e. Before any charge should be filed in the CID, a preliminary
investigation must be conducted to determine if there is
sufficient cause to charge the respondent for deportation.
4. Petition of Feeder International is DENIED.