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Taxation Case Law Overview

This document outlines the key doctrines, principles, and cases related to taxation in the Philippines. It discusses the basis of taxation, nature of taxation, and doctrines like prospectivity of tax laws, non-retroactivity of rulings, and imprescribibility of taxes. It also examines the scope and limitations of taxation, including inherent limitations like territoriality and the non-delegability of taxation powers. Constitutional limitations discussed include the uniformity and equality clause, non-impairment of contracts clause, due process clause, and tax exemptions for religious, educational, and charitable institutions. Leading cases are cited for each topic.

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Mary Fatima Berongoy
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121 views3 pages

Taxation Case Law Overview

This document outlines the key doctrines, principles, and cases related to taxation in the Philippines. It discusses the basis of taxation, nature of taxation, and doctrines like prospectivity of tax laws, non-retroactivity of rulings, and imprescribibility of taxes. It also examines the scope and limitations of taxation, including inherent limitations like territoriality and the non-delegability of taxation powers. Constitutional limitations discussed include the uniformity and equality clause, non-impairment of contracts clause, due process clause, and tax exemptions for religious, educational, and charitable institutions. Leading cases are cited for each topic.

Uploaded by

Mary Fatima Berongoy
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© © All Rights Reserved
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BASIS OF TAXATION:

 PILMICO-MAURI FOODS CORP. v. CIR 802 SCRA 618


 CIR vs. ALGUE 158 SCRA 17
 First Lepanto Taisho Insurance v. CIR 695 SCRA 639
 CIR v. Pineda, 21 SCRA 105
 CIR v. CTA, 234 SCRA 348

NATURE OF TAXATION:
 Republic v. Caguioa, 536 SCRA 193
 Mactan Cebu International Airport Authority v. Marcos, 261 SCRA 667
 WALTER LUTZ v J. ANTONIO ARANETA

DOCTRINES IN TAXATION:

Prospectivity of Tax Laws: Lorenzo v. Posadas, G.R. No. L-43082, June 18, 1937
Non-Retroactivity of Rulings : CIR v. Burroughs, Inc., 142 SCRA 324[1986]
Imprescribibility of Taxes: CIR v. Ayala Securities Corporation, G.R. No. L-29485, November 21,
1980
Kasamahan Realty Development Corporation v. CIR, CTA Case No. 6204,
February 16, 2005
Compensation/ Set Off: Domingo v. Garlitos, G.R. No. l-18994, June 29, 1963
CIR v. Cebu Portland Cement Company (December 15, 1987)
SMI-ED Philippines Technology, Inc. v CIR, G.R. No. 175410, November
12, 2014, 739 SCRA 691
Double Taxation : Pepsi Cola v. Tanawan, 69 SCRA 460
City of Manila, et.al v. Coca-cola Bottlers Philippines, Inc. G.R. No.
181845, August 4, 2009
Nursery Care Corporation, et. Al v. Acevedo etc, et.al., G.R. No.
180651, July 30, 2014

Characteristics of Taxation Cases:


 Planters Products, Inc. v. Fertiphil Phil. Corporation, 548 SCRA 485
 Tio v. Videogram Regulatory Board, et al., 151 SCRA 213

Scope and Limitations of Taxation

1. Inherent Limitations

a. Power of taxation is inherently legislative in character


 Pepsi-Cola Bottling Co. v. Mun. Of Tanuan, Leyte, 69 SCRA 460

b. Taxation is for a public purpose


 Planters Products, Inc. v. Fertiphil Corp., 548 SCRA 485
c. Taxation is territorial
 ACMDC v. CIR, 524 SCRA 73

d. Taxation is subject to international comity Cases:


 CIR v. Mitsubishi Metal Corp., 181 SCRA 214
 CBK Power Co., Ltd. v. CIR, GR No. 192283, January 14, 2015

e. Non-delegability of the power of taxation


 Southern Cross Cement Corp. v. Cement Manufacturers Asso. Of the Phils., GR No. 158540,
August 3, 2005

f. Government is exempt from taxation


 City of Lapu Lapu v. PEZA, 742 SCRA 524
 MIAA v. Parañaque City, 495 SCRA 591
 Mactan-Cebu International Airport Authority (MCIAA) v. City of Lapu-Lapu, 757 SCRA 323

2. Constitutional Limitations

a. Uniformity and Equality Clause Cases:


 CIR v. SM Prime Holdings, Inc., 613 SCRA 774
 PAGCOR v. CIR, 645 SCRA 338
 Phil. Trust BL Company v. Yatco, 69 Phil 420
 Tan v. Del Rosario, 237 SCRA 324
 British Tobacco v. CIR, 562 SCRA 511
 Punsalan v. City of Manila, 95 Phil 46
 Pepsi Cola Bottling Co., Inc. v. City of Butuan, 24 SCRA 789

b. Non-impairment of Contract Clause


Cases:
 Mactan Cebu International Airport Authority v. Marcos, 261 SCRA 667
 Tolentino v. Sec. of Finance, 235 SCRA 630 c. Due Process Clause Cases:
 PB Communications v. CIR, 302 SCRA 241

c. Due Process Clause


Cases:
 CIR v. Metro Star Superama, Inc., 637 SCRA 633
 Carlos Superdrug Corp. v. DSWD G.R. 166494 June 29, 2007

d. Tax exemptions of religious, educational and charitable institutions/organizations from property


tax Cases:
 CIR v. YMCA, 298 SCRA 83
 Lladoc v. CIR, 14 SCRA 292
 Hodges v. Mun. Board of Iloilo City, 19 SCRA 28
 Lung Cancer of the Philippines v. QC, 433 SCRA 119
 St. Luke's Medical Center, Inc. v. CIR, 682 SCRA 66
 Angeles University Foundation v. City of Angeles, 675 SCRA 359

e. Free Exercise of Religious Profession and Worship Cases:


 American Bible Society v. City of Manila, 101 Phil 386
 Tolentino v. Secretary of Finance, 235 SCRA 630

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