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Commissioner of Customs Vs. Court of Tax Appeals, Las Islas Filipinas Food Corp. & Pat-Pro Overseas Co. Ltd.

COMMISSIONER OF CUSTOMS, Petitioner, versus COURT OF TAX APPEALS, LAS ISLAS FILIPINAS FOOD CORPORATION and PAT-PRO VERSEAS CO., LTD., Respondents.

G.R. No. 171516-17 | 2009-02-13

R E S O L U T I O N


CORONA, J.:

Respondent Las Islas Filipinas Food Corporation (LIFFC) owned and operated an industry-specific customs bonded warehouse catering to food manufacturers.[1] Among the conditions for its establishment and operations was securing an import allocation from the Sugar Regulatory Administration (SRA) every time it imported sugar for its clients.[2]

On February 20, 2004, Pat-Pro Overseas Company, Ltd. (PPOC), a Thai company, appointed LIFFC as its "exclusive offshore trading, storage and transfer facility" in the Philippines for its local and foreign transshipment[3] operations.[4] Pursuant to this appointment,...