IT IS A WELL ACCEPTED PRINCIPLE THAT WERE A STATUTE IS AMBIGUOUS, COURTS MAY EXAMINE BOTH THE PRINTED PAGES OF THE PUBLISHED ACT AS WELL AS THOSE EXTRINSIC MATTERS THAT MAY AID IN CONSTRUING THE MEANING OF THE ST S TATUTE, SUCH AS THE HISTORY OF ITS ENACTMENT ENACTMENT,, THE REASONS FOR THE PASSAGE OF THE BILL AND PURPOSES TO BE ACCOMPLISHED BY THE MEASURE.
COMMISSIONER OF CUSTOMS, petitioner, vs. ESSO STANDARD EASTERN, INC., (Formerly S!"#$"r$%&"'m Re)#*#+ Cor. (P-*l., respondent. G.R. No. L%/01/2 A+3! 45, 4256 FACTS Respondent ESSO is the holder of Rening Concession No. 2, issued by the Secretary of Agriculture and Natural Resources on December , !"#, and operates a petroleum rening plant in $imay %ataan. &nder Ar!*'le 471 o8 Re9l*' A'! No. 105 'hich provides( )During the ve years follo'ing the granting of any concession, concession, the concessionaire concessionaire may import free of customs duty, all e*uipment, machinery, material, instruments, supplies and accessories,) respondent imported and 'as assessed the special import ta+ 'hich it paid under protest-. Court procedures: he Collector of Customs on /ebruary /ebruary !0, !02, !02, held that respondent respondent 1SS 1SS 'as sub3ect to the payment of the special import ta+ provided in Re9l*' A'! No. 412:, as amended by R.A. No. 2352, 2352 , and dismissed the protest. n 4arch !, !02, respondent appealed the ruling of the Collector of Customs to the Commissioner of Customs 'ho, on 4arch !, !0", a5rmed the decision of said Collector of Customs. 1 n 6uly 2, !0", respondent 1SS led a petition 'ith the Court of a+ Appeals for revie' of the decision of the Commissioner of Customs. he Court of a+ Appeals, on September 78, !0#, reversed the decision of herein petitioner Commissioner of Customs and ordered refund of the amount of 9##".02 to respondent 1SS 'hich the latter had paid under protest. Statutes subject of construction:
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R.A. NO. 105 (PETROLEUM ACT OF 42:2 – title, Art. !3, Art. !2, Art. !"#
9 R.A. NO. 412: (SPECIAL TAX LAW, as amended by R.A. No. /16/ % title ISSUE :N the e+emption en3oyed by herein private respondent 1SS from custom duties granted by R.A. NO. 105 (PETROLEUM ACT OF 42:2 should embrace or include the special import ta+ imposed by R.A. NO. 412: (SPECIAL TAX LAW.
HELD ;es. 9etition denied. o
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he title of R.A. No. !7< Special a+ $a'- indicates unmista=ably that it is repealing si+ prior statutes all these la's dealt 'ith the imposition of a special e+cise ta+ on foreign e+change or other form of levy on importation of goods into the country-. n the other hand, it is apparent that R.A. No. 7># he 9etroleum Act-, has not been repealed although this la' had granted more concessions and ta+ e+emption privileges than any of the statutes that 'ere amended, repealed or revo=ed by R.A. No. !7<. he CN?R1SS / @1 9@$99N1S sa' t to preserve the privileges granted under the 9etroleum $a' of !< in order to =eep the door open to e+ploitation and development of the petroleum resources of the country. he SC is convinced that R.A. No. 7># or the 9etroleum Act of !< 'as intended to encourage the e+ploitation, e+ploration and development of the petroleum resources of the country by giving it the necessary incentive in the form of ta+ e+emptions. his is the raison dB etre for the generous grant of ta+ e+emptions to those 'ho 'ould invest their nancial resources to'ards the achievement of this national economic goal.
