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not be in accord with the rule that a corporation is vested by law with a personality that is separate and distinct from those of the persons composing it, as well as from that of any other legal entity to which it may be related (Sunio, et al. v. National Labor Relations Commission, et al., G.R. No. 57767, Jan. 31, 1984 cited in Torres, Law of Business Organizations, p. 126). Be that as it may, however, stockholders may be held liable for the unpaid taxes of a dissolved corporation if it appears that the corporate assets have passed into their hands (Tan Tiong Bio v. Commissioner of Internal Revenue, L-15778, Apr. 23, 1962), or when stockholders have unpaid subscriptions to the capital of the corporation. Similarly, estate taxes accruing upon transmission of the decedent's estate to his heirs are not liabilities which can be enforced against his heirs, for estate taxes are supposed to be obligations that. must be paid by the executor/administrator out of the net estate, before delivery to any beneficiary of his distributive share. However, if prior to the payment of the estate tax due on the transfer of decedent's estate, the properties of the deceased are distributed to any beneficiary, then such beneficiary shall be subsidiarily liable for the payment of such portion of the estate tax as his distributive share bears to the total value of the net estate (Sec. 91{C], National Internal Revenue Code of 1997 hereafter, 1997 NIRC)). NATURE OF THE TAXING POWER. The power to tax is an attribute of sovereignty. It is inherent in the State. As an incident of sovereignty, the power to tax has been described as “unlimited in its range, acknowledging in its very nature no limits, so that security ‘against its abuse is to be found only in the responsibility of the legislature which imposes the tax on the constituency who are to pay it” (Mactan Cebu International Airport Authority v. Marcos, etc. et al., G.R. No, 120082, Sept. 11, 1996). In one decided case, the Supreme Court called it an awesome power. However, no matter how awesome it may be, it must not be exercised arbitrarily (Commissioner of Internal Revenue v. Algue, Inc., supra). ‘Taxation is a power emanating from necessity; a necessary burden to preserve the State's sovereignty, and a means to give the citizenry an army to resist an aggression, a navy to defend its shores from invasion, a corps of civil servants to serve, public improvement designed for the enjoyment of the citizenry and those which come within the State's territory and facilities, and protection which a GE ERAL PRINCIPLES government is supposed to provide (Philippine Guaranty Co., Ine. v. Commissioner of Internal Revenue, et al., supra). As stated in one case (Luzon Stevedoring Corp. v. CTA, et al., L-30232, July 29, 1988), taxation is a high prerogative of sovereignty the relinquishment of which is never presumed, and any reduction or diminution thereof with respect to its mode or rate must be strictly construed and the same must be couched in clear terms. The general rule is that any claim for exemption from tax statutes should be construed strictly against the taxpayer. Incidentally, the power to tax is not granted in the Constitution. Constitutional provisions relating to the power of taxation do not operate as grants of the power of taxation to the Government, but instead merely constitute limitations upon a power which would otherwise be practically without limit. As already mentioned, the taxing power is peculiarly and exclusively legislative in character and remains undiminished in the legislature in the absence of an express surrender thereof, clear and explicit in its terms (61 Am. Jur. 71-73). ‘The power to tax is subject to inherent and constitutional limitations PURPOSES AND OBJECTIVES OF TAXATION (a) Revenue - Basically, the purpose of taxation is to provide funds or property with which the State promotes the general welfare and protection of its citizens (51 Am. Jur. 71-73). (b) Regulation - Taxation also has a regulatory purpose as in the case of taxes levied on excises or privileges like those imposed on tobacco and aleoholie products, or amusement places like night clubs, cabarets, cockpits, ete, ‘Taxation is not merely a power that is exercised in order to raise revenue for the support of the Government. Taxes may also be imposed for a regulatory purpose as, for instance, in the rehabilitation and stabilization of a threatened industry which is affected with public interest, like the oil industry (Caltex Philippines, Inc. v. Commission on Audit, et al., G.R. No. 92585, May 8, 1992). (©) Promotion of General Welfare - In one decided case, the Supreme Court ruled that taxation may be used as an implement of the police power in order to promote the general welfare of the people. ‘Thus, in the case of Lutz v. Araneta (98 Phil. 148), the Supreme Court upheld the validity of the Sugar Adjustment Act, which imposed a tax on milled sugar since the purpose of the law was to