In the liquidation of a company, in the absence of a specific law that may have given preference to the claims of the Government at the relevant time, priority would depend on which encumbrance was earlier in time—However, where the claim of the Government was contemporaneous with any other claimant, the claim of the Government would prevail—In addition to the fact that the Banks had their claim earlier in time to the Government’s claim, the Banks were secured creditors as they held registered mortgages of the company’s immovable properties—Claim of the Government also did not charge the said mortgaged properties, which may have created a priority of claim over that of the mortgages (Banks)—Government (i.e. customs authorities) had no entitlement to any amount realized from the sale of the mortgaged properties.