The Court of Tax Appeals (CTA) has denied for lack of jurisdiction the petition filed by a businesswoman against the Bureau of Customs (BOC) over the seizure of seven vintage magazines stuffed with collectible banknotes.

Collectible banknotes, like vintage magazines, "are sought after by collectors for a variety of reasons, including their rarity, design, or historical significance."

Sigrid Carandang, who operates a business registered with the Department of Trade and Industry (DTI) as Minted MNL and is the local franchise holder of Numismatic Guaranty Corporation (NGC) in the United States, filed a Petition for Review before the CTA on May 20, 2021.

The petition involved the shipment covered by FEDEX Airway Bill (AWB) No. 771094237958 that was transported from Harbour City, Hong Kong to Carandang's address in the Philippines on July 27, 2020. The sender described the parcel as containing collectible magazines with a total declared value of $100.

However, Carandang received a message notification on Aug. 3, 2020 stating that the shipment was recommended for seizure as the declaration of the seven pieces of collectible magazines was found to be 70 pieces instead.

Carandang then sent an email to FEDEX Clearing Department to clarify that the shipment in truth and fact contained seven pieces of magazines, and the sender only used a big UPS box as there's no smaller one available to protect the magazines.

An actual examination of the subject shipment revealed that it did contain seven pieces of magazines. However, inserted between the pages of those magazines were several collectible notes.

Carandang then explained that the shipper of the collectible magazines and notes failed to declare the same properly, adding that it was only for security reasons and without intention to mislead. She also clarified that the collectible notes were given to her as tokens of friendship and nothing more.

Despite several follow-ups, the subject shipment was still recommended for seizure. The BOC issued a Warrant of Seizure and Detention on Oct. 27, 2020 ordering the seizure of Carandang's shipment for violation of Section 1400 in relation to Section 1113 of the Customs Modernization and Tariff Act (CMTA).

When the BOC denied Carandang's offer of settlement on Dec. 3, 2020 and her appeal on Feb. 26, 2021, she elevated the case to the CTA.

After carefully evaluating both their arguments, the CTA said that it lacked jurisdiction over the subject matter and the petition dated May 20, 2021 was not timely filed before the CTA.

"If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits. Therefore, this Court is left without a choice but to dismiss this case, and will no longer belabor to discuss the merits of petitioner's claim," the decision said.

The 13-page decision was written by Associate Justice Maria Rowena Modesto-San Pedro with the concurrence of Associate Justices Ma. Belen M. Ringpis-Liban and Corazon G. Ferrer-Flores.