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    Case Digest - G.R. No. L-28329 - Commissioner of Customs vs. Esso Standard Eastern, Inc.

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    Jeriel Ivan

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    Case Digest - G.R. No. L-28329 - Commissioner of Customs vs. Esso Standard Eastern, Inc.

    Uploaded by

    Jeriel Ivan
    18 views2 pages

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    Case Digest_ G.R. No. L-28329 - Commissioner of Customs vs. Esso Standard Eastern, Inc.

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    18 views2 pages

    Case Digest - G.R. No. L-28329 - Commissioner of Customs vs. Esso Standard Eastern, Inc.

    Uploaded by

    Jeriel Ivan

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 2

    Title

    Commissioner of Customs vs. Esso Standard Eastern, Inc.

    Case Decision Date


    G.R. No. L-28329 Aug 7, 1975

    The Supreme Court ruled in favor of Esso Standard Eastern, Inc., stating that the
    exemption from customs duties granted to Esso under the Petroleum Act of 1949
    includes exemption from the special import tax imposed by R.A. 1394.

    Case Digest (G.R. No. L-28329)


    Comprehensive
    Facts:
    The case "Commissioner of Customs v. Esso Standard Eastern, Inc." involves the
    respondent, Esso Standard Eastern, Inc. (formerly Standard-Vacuum Refining
    Corporation (Phil.)), and the petitioner, the Commissioner of Customs. The dispute arose
    over the imposition of a special import tax amounting to P775.62 on certain articles
    imported by Esso under Republic Act No. 387, also known as the Petroleum Act of 1949.
    Esso, holding Refining Concession No. 2 issued on December 9, 1957, operates a
    petroleum refining plant in Limay, Bataan. Under Article 103 of the Petroleum Act, Esso
    imported various items free of customs duty but was assessed a special import tax,
    which it paid under protest. The Collector of Customs upheld the tax imposition, and the
    Commissioner of Customs affirmed this decision. Esso then appealed to the Court of Tax
    Appeals, which reversed the Commissioner's ruling and ordered a refund. The
    Commissioner of Customs subsequently petitioned the Supreme Court to reverse the
    Tax Court's decision, arguing that the special import tax under Republic Act No. 1394 is
    distinct from customs duties and that the exemption under the Petroleum Act does not
    cover the special import tax.

    Issue:
    1. Does the term "customs duty" in Article 103 of Republic Act No. 387 include the
    special import tax imposed by Republic Act No. 1394?
    2. Does the exemption from payment of customs duties under Republic Act No. 387
    include exemption from the payment of the special import tax?

    Ruling:
    The Supreme Court ruled in favor of Esso Standard Eastern, Inc., affirming the decision
    of the Court of Tax Appeals. The Court held that the exemption from customs duties
    granted under the Petroleum Act of 1949 includes the special import tax imposed by
    Republic Act No. 1394.

    Ratio:
    The Supreme Court's decision was based on principles of statutory construction and the
    legislative intent behind the relevant statutes. The Court emphasized that when a statute
    is ambiguous, courts may consider extrinsic aids such as the history of the statute, the
    reasons for its enactment, and the purposes it aims to achieve. The Petroleum Act of 1949
    was designed to promote the exploration, development, and utilization of the
    Philippines' petroleum resources by providing significant tax exemptions. The Court
    found that the legislature intended to continue these incentives to foster the petroleum
    industry's growth. The Court also noted that Republic Act No. 1394, which imposed the
    special import tax, did not explicitly repeal or amend the tax exemptions provided under
    the Petroleum Act. Therefore, the Court concluded that the special import tax is covered
    by the customs duty exemption granted to Esso under the Petroleum Act. The Court
    further held that repeal by implication is not favored unless the legislative intent to
    repeal is clear and manifest, which was not the case here.

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