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The Commissioner of Customs, et al. vs. New Frontier Sugar Corporation

THE COMMISSIONER OF CUSTOMS & THE DISTRICT COLLECTOR OF CUSTOMS FOR THE PORT OF ILOILO, Petitioners, vs. NEW FRONTIER SUGAR CORPORATION, Respondent.

G.R. No. 163055 | 2014-06-11

SECOND DIVISION
 
DECISION

PEREZ, J.:
 
Before the Court is a Petition for Review on Certiorari seeking to reverse and set aside the 29 March 2004 Decision1 of the Court of Appeals  (CA) in CA-G.R. SP No. 48842 which affirmed the Decision and Resolution dated 19 June 1998 and 23 July 1998, respectively, of the Court of Tax Appeals (CTA)2 in C.T.A. Case No. 5347.

The Facts
 
As both found by the trial court and appellate court, the factual antecedents3 of the case are as follows:

Petitioners are the duly appointed Commissioner of Customs, and the District Collector of Customs for the Port of Iloilo....