1.
UNIFORMITY AND EQUITY IN TAXATION
     - same class, same rate
     -   classification of taxpayers, subject or items to be taxed
             The rule of taxation shall be uniform and equitable (Sec.28 (1), Art. III, 1987
              Constitution).
             The tax is uniform when it operates with the same force and effect in every place where
              the subject of it is found. "Uniformity" means all property belonging to the same class
              shall be taxed alike. It does not signify an intrinsic, but simply a geographic, uniformity
              (Churchill & Tait vs. Conception, 34 Phil. 969). Uniformity does not require the same
              treatment; it simply requires reasonable basis for classification.
             The concept of equality in taxation requires that the apportionment of the tax burden be
              more or less just in the light of the taxpayer’s ability to shoulder the tax burden and if
              warranted, on the basis of the benefits received from the government. Its cornerstone
              is the taxpayer’s ability to pay.
Uniformity v. equity in taxation
        The concept of uniformity in taxation implies that all taxable articles or properties of the
         same class shall be taxed at the same rate.  It requires the uniform application and operation,
         without discrimination, of the tax in every place where the subject of the tax is found. It does
         not, however, require absolute identity or equality under all circumstances, but subject to
         reasonable classification.
·                     The concept of equity in taxation requires that the apportionment of the tax burden be,
                more or less, just in the light of the taxpayer’s ability to shoulder the tax burden and, if
                warranted, on the basis of the benefits received from the government.  Its cornerstone is the
                taxpayer’s ability to pay.