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ONG, as 'An Act Adopting the Simplified Net Income Taxation Scheme For The Self-Employed
COMMISSIONER OF INTERNAL REVENUE and Professionals Engaged In The Practice of Their Profession, Amending Sections 21
G.R. No. 109446 Octofdsfdsfdsber 3, 1994 and 29 of the National Internal Revenue Code,' as amended. Petitioners also contend
it violated due process.
- Article VI, Section 28(1) — The rule of taxation shall be uniform and equitable. The 2. What is apparent from the amendatory law is the legislative intent to increasingly
Congress shall evolve a progressive system of taxation. shift the income tax system towards the scheduler approach in the income taxation
of individual taxpayers and to maintain, by and large, the present global treatment
- Article III, Section 1 — No person shall be deprived of . . . property without due on taxable corporations. The Court does not view this classification to be arbitrary
process of law, nor shall any person be denied the equal protection of the laws. and inappropriate.
G.R. No. L-59431 July 25, 1984 When the problem of classification became of issue, the Court said: "Equality
and uniformity in taxation means that all taxable articles or kinds of property of
FACTS the same class shall be taxed the same rate.
The taxing power has the authority to make reasonable and natural
Section 1 of BP Blg . 135 amended the Tax Code and petitioner Antero M. Sison,
classifications for purposes of taxation..." As provided by this Court, where "the
as taxpayer, alleges that "he would be unduly discriminated against by the
differentation" complained of "conforms to the practical dictates of justice and
imposition of higher rates of tax upon his income arising from the exercise of his
equity" it "is not discriminatory within the meaning of this clause and is
profession vis-a-vis those which are imposed upon fixed income or salaried
therefore uniform."
individual taxpayers. He characterizes said provision as arbitrary amounting to
class legislation, oppressive and capricious in character. It therefore violates
both the equal protection and due process clauses of the Constitution as well as
of the rule requiring uniformity in taxation.
ISSUE
Whether or not the assailed provision violates the equal protection and due process
clauses of the Constitution while also violating the rule that taxes must be uniform
and equitable?
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