Acting Commissioner of Customs v. Court of Tax Appeals

Summary

American businessman Charles Andrulis was caught at Manila International Airport attempting to leave the Philippines with substantial foreign currencies (US $59,639.00, Indonesian Rupiah, Singapore dollars) without Central Bank authorization. The customs authorities initiated forfeiture proceedings under customs and central bank regulations. While the Court of Tax Appeals reversed the forfeiture citing general presumptions of ownership, the Supreme Court reinstated the forfeiture decision, emphasizing that the specific burden of proof provisions in customs law override general presumptions. The Court held that in customs forfeiture proceedings, the claimant bears the burden to prove legitimate possession once probable cause is established. Andrulis failed to provide convincing evidence that he legally brought the currencies into the country, particularly given his suspicious behavior and history of absconding from hotel bills.