OLSEN v ALDANESEF: --SY MAN v JACINTOF: Several shipments of
textile and sewing machines consigned to the P were ordered seized
by the Collector of Customs of Manila. The CC, after a hearing,
rendered a decision where the articles would be delivered to P
after payment of the necessary customs duty EXCEPT the sewing
machines. P received a copy of the decision on June 27, and on July
12, he sent another letter asking for execution as the decision had
already become final and could no longer be reviewed past the 15
day reglementary period. The CC recognized receipt, and their
letter was endorsed to the Commissioner, who did not reply to it
(it seems he was reviewing their case).P then filed a case of CPM
against the CC, questioning the review of the CCM and ordering
delivery of shipment of the textiles. The TC granted the petition
and ordered its execution on the ground that the decision became
final. Hence this appeal to the SC.Arguments: Commissioner's power
under RAC of supervision and control over the Collectors allows
review and revision of decisions of Collector even when not
appealed. This is the basis of a memo order that was the basis of
his actions.Reply: Not so. When not appealed, it becomes final to
both sides.I: Whether or not the Commissioner of Customs may rely
on his supervision and control power under the AC to review
Collector decisions motu propio.The RAC allows for an appeal
procedure under Sec. 1380 (person aggrieved may give written notice
within 15 days to signify intent to have Comm review). In addition,
the Commissioner also has supervisory authority under Sec. 1393,
where the Comm may order a reliquidation if the decision was
erroneous and unfavorable to the government.It did not seem to
refer to seizure cases, just routinary cases. There is the
presumption that in seizure cases, the government has already acted
based on how best to protect its interests, subject only to the
appeal provision. There is also Sec. 1378 where the Commissioner,
once informed by the Collector of the seizure, must make his
decision at a resonable time. At any rate, finality applies also to
the government.(if the law does not provide, the rule cannot
create)--PEOPLE v MACERENF: Private respondents/accused were
charged in the MC Sta. Cruz, Laguna of having violated Fisheries
Administrative Order No. 84-1 for allegedly resorting to electro
fishing in a freshwater river. The MC granted the motion to quash
for lack of cause of action as the law being cited, Sec. 11 of the
Fisheries Law, did not provide for electro fishing as an 'obnoxious
or poisonous substance', violation of which would lead to fine
