In the month of Aprils 1906, the plaintiffs imported into the Philippine Islands certain cotton goods, upon  which the Collector of Customs imposed a duty under paragraph (c) of article 117 of the tariff laws applicable to the Philippine Islands,^[1]  and in addition thereto  a surtax  of 30 per cent under paragraph (g) of said article. Against this ruling of the Collector of Customs the plaintiffs entered a protest, and appealed from the decision of the Collector to the Court of First Instance of the city of Manila.  After hearing the evidence, the said Court of First Instance affirmed the ruling of the Collector of Customs, from which decision the plaintiffs appealed to this court.

The customs authorities classified the importation  under paragraph (c) of article 117 of the Customs Tariff Schedule  as "textiles,  plain and without figures,  stamped  or printed, not measuring over one hundred centimeters in width, weighing  8 kilograms or more per one hundred square meters, and  from 26 to 38 threads net weight," and  assessed the importation at 18 cents per kilo, plus a surtax of 30 per cent.  The plaintiffs contend that the surtax of 30 per cent, under paragraph (g) of said article, was  illegally imposed.  Article 117 reads as follows^[2]:

"117. Textiles, plain and without figures, napped or not, weighing ten kilos or more per one hundred square meters, unbleached, bleached, or dyed; and

"Textiles, plain and without figures, stamped or printed, napped or not, measuring not over sixty-five centimeters in width, weighing eight kilos or more per one hundred square meters; and

"Textiles, plain and without figures, not stamped or printed, whatever be their width, weighing eight kilos or more per one hundred square meters, having

"(a) Up to eighteen threads, N. W., kilo, ten cents;

"(b) From nineteen to thirty-one threads, N. W., kilo, fourteen cents.

"(c) From thirty-two to thirty-four threads, N,  W., kilo, eighteen cents.

"(d) From thirty-five to thirty-eight threads, N.  W., kilo, twenty-four cents.

"(e) From thirty-nine to forty-four threads, N.  W., kilo, twenty-eight cents.

"(f) Forty-five threads or more, N. W., kilo, thirty-two cents.

"(g) The same textiles, stamped, printed, or manufactured with the dyed yarns,  dutiable as the textile,  with a surtax of thirty  per centum.

"[NOTE Textiles woven with a colored  yarn on the selvage or with a colored selvage stripe not exceeding two millimeters in width  shall not be considered as manufactured with dyed yarns.]"

The Collector of Customs held, in effect,  that the last paragraph (g), imposing a surtax upon textiles stamped, printed or manufactured with dyed yarn, clearly refers to all descriptions which precede it and therefore all textiles, when printed, stamped or manufactured with dyed yarns should be subjected to a surtax of 30 per cent.  The Collector further held that this interpretation of said article had been followed since November 12, 1901, and that the law in the meantime had been amended twice, without the Legislature having made any change in that portion  of said article.

It is a rule well established in the interpretation of customs  laws that, where there has been a long acquiescence in a regulation by which the rights of parties for years have been determined and adjusted, such interpretation should be followed in the absence of the most cogent and persuasive reasons to the contrary.  (Robertson vs. Downing, 127 U. S., 607; U. S. vs. Healey, 160  U.S., 136; Merritt vs. Cameron, 137  U. S., 542.)

The only error assigned by the appellants is that "the lower court erred in approving the imposition of the duty (surtax) made by the Collector" and argue that the last paragraph (g) of said article 117 does not apply to the goods mentioned in paragraph 3 of said article.  Said paragraph 3 (unnumbered)  relates to textiles, plain  and without figures, not stamped or printed.  It is clear that the  last  paragraph (g), does not apply to the textiles mentioned in said paragraph 3, because paragraph (g) only refers to textiles  stamped, printed, etc.  Whenever textiles are stamped, printed, etc., they do not come under the  description given in said paragraph 3, and, therefore, paragraph (g), because it refers only to textiles stamped, printed, etc., has no application to said paragraph 3.

Paragraphs 1, 2, and 3 of article 117 enumerate the textiles upon  which duty is imposed.  Paragraphs (a) to (f) fix the duty upon those textiles, under the conditions mentioned in said paragraphs (a) to (f).  Paragraph (g) imposes  a surtax upon all the textiles mentioned under article 117 when said textiles  are in the  condition mentioned in said paragraph (g).  Paragraph (g) might be read "These same textiles mentioned above, when they are  stamped, printed, etc., are subject to a surtax of 30 per cent."

Our conclusion is, therefore, that the textiles in controversy being stamped, printed, etc., are subject to a surtax of 30 per cent, and that the judgment of the lower court should be affirmed, with costs.  So ordered.

Arellano, C. J., Torres, Mapa,, and Tracey, JJ., concur.
Carson and Willard, JJ., dissent.

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^[1] Act of Congress of March 3, 1005, par. 117 (c) (4 Pub.  Laws,  174).

^[2] Act of Congress of February 26, 1906, par, 117 (5 Pub. Laws, 435).