Scribd
Upload
9 views5 pages

Cases 1

The Court addressed the effective date and applicability of Republic Act 7167, determining it took effect on January 30, 1992, and applies to income earned in 1991, invalidating conflicting provisions in Revenue Regulations No. 1-92. In a separate case, the Court upheld the constitutionality of Section 14 of Republic Act No. 9006, ruling that its repeal of Section 67 of the Omnibus Election Code was germane to the act's purpose of ensuring credible elections and did not violate the equal protection clause. The Court confirmed the petitioners' standing and dismissed their petitions without costs.

Uploaded by

m.estacion.518755
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
9 views5 pages

Cases 1

The Court addressed the effective date and applicability of Republic Act 7167, determining it took effect on January 30, 1992, and applies to income earned in 1991, invalidating conflicting provisions in Revenue Regulations No. 1-92. In a separate case, the Court upheld the constitutionality of Section 14 of Republic Act No. 9006, ruling that its repeal of Section 67 of the Omnibus Election Code was germane to the act's purpose of ensuring credible elections and did not violate the equal protection clause. The Court confirmed the petitioners' standing and dismissed their petitions without costs.

Uploaded by

m.estacion.518755
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 5

In the consolidated cases stemming from petitions for mandamus

and prohibition, the Court primarily addressed two issues: the


effective date of Republic Act 7167 and its applicability to income
earned in 1991. The Court determined that Rep. Act 7167, which
adjusts personal and additional income tax exemptions, took effect
on January 30, 1992—fifteen days after its publication on January 14,
1992—as stated in Article 2 of the Civil Code. Consequently, this law
applies to compensation income earned or received during the
calendar year 1991, as it was aimed at alleviating the tax burden on
individual taxpayers and responding to increased living costs since
the last adjustments in 1986. The Court invalidated provisions in
Revenue Regulations No. 1-92 that deferred the implementation of
these exemptions to 1992, stating they contradicted the statute's
intent. Therefore, taxpayers who filed returns in 1992 without the
benefit of the increased exemptions were entitled to refunds or
credits based on provisions of Rep. Act 7167. Separate opinions
expressed varied views on the publication requirement, with one
justice asserting the law's effectiveness could stand independently
of publication, while others upheld the publication necessity derived
from previous case law. Ultimately, the ruling reinforced the
legislative goal of providing relief to lower and middle-income
earners.
FARINAS v EXECUTIVE SECRETARY
FACTS:
In G.R. Nos. 147387 and 152161, the Supreme Court held that
Section 14 of Republic Act No. 9006, which repealed Section 67 of
the Omnibus Election Code, was constitutional. The Court ruled that
the repeal was not a "proscribed rider" under Section 26(1), Article
VI of the Constitution, and was germane to the general subject of
the act, which was to enhance the holding of free, orderly, honest,
peaceful and credible elections through fair election practices. The
Court also found that there was no equal protection clause violation,
as a substantial distinction existed between elective and appointive
officials, and that the treatment of these officials under Section 67
and Section 66 of the Omnibus Election Code, respectively, was not
arbitrary or oppressive.
RULING:
In resolving the procedural issue regarding the petitioners' standing,
the Court concluded that the petitioners, as members of the House
of Representatives, taxpayers, and registered voters, possess legal
standing to challenge the constitutionality of Section 14 of Republic
Act No. 9006. The Court noted that while generally a party must
demonstrate a personal stake in the outcome, it has adopted a more
liberal approach in cases of significant societal impact, particularly
given the impending national elections. The Court then addressed
the merits of the petitions and determined that the repeal of Section
67 of the Omnibus Election Code did not violate the "one subject-
one title" rule, as the title of Rep. Act No. 9006 adequately
encapsulated the law's objectives. Additionally, the Court found that
the repeal did not infringe on the equal protection clause,
recognizing legitimate distinctions between elective and appointive
officials. The Court also upheld the "enrolled bill doctrine," rejecting
claims of procedural irregularities during the enactment process and
confirming that the law would take effect after compliance with
publication requirements. Consequently, the petitions were
dismissed with no pronouncement on costs.

You might also like