Whether the increased personal and additional exemptions provided by R.A.

9504 should be applied to the entire taxable year 2008 or prorated,

considering that R.A. 9504 took effect only on 6 July 2008.

DECISION: The personal and additional exemptions established by R.A. 9504

should be applied to the entire taxable year 2008

The prorated application of the new set of personal and additional

exemptions for the year 2008, which was introduced by respondents, cannot
even be justified under the exception to the canon of non-delegability; that
is, when Congress makes a delegation to the executive branch. The
delegation would fail the two accepted tests for a valid delegation of
legislative power; the completeness test and the sufficient standard test. The
first test requires the law to be complete in all its terms and conditions, such
that the only thing the delegate will have to do is to enforce it. The sufficient
standard test requires adequate guidelines or limitations in the law that map
out the boundaries of the delegate's authority and canalize the delegation.

In this case, respondents went beyond enforcement of the law, given the
absence of a provision in R.A. 9504 mandating the prorated application of
the new amounts of personal and additional exemptions for 2008. Further,
even assuming that the law intended a prorated application, there are no
parameters set forth in R.A. 9504 that would delimit the legislative power
surrendered by Congress to the delegate. In contrast, Section 23(d) of the
1939 Tax Code authorized not only the prorating of the exemptions in case
of change of status of the taxpayer, but also authorized the Secretary of
Finance to prescribe the corresponding rules and regulations.