Topic: Debt enforcing of which, the personal consent of the individual is

Republic v Mambulao not required.

Facts – Mambulao Lumber Co. (MLC) is liable in the aggregate

sum of P4.8k to the Republic of the Philippines for “forest
charges.” Prior to this, MLC has paid an aggregate sum of
P9.1k for “reforestation charges.” MLC contends that since
their payment of P9.1k was not used by the Republic for
reforestation, the Republic should refund the P9.1k paid by
MLC to the latter, or at least the sum be applied to the P4.8k
forest charge. (Gusto nila i-set-off)

Issue – WON the sum paid by MLC as reforestation charges

may be set off against the payment of forest charges – NO

Held – There is nothing in the law which requires that the

amount collected as reforestation charges should be used
exclusively for the reforestation of the area covered by the
license, and that if not so used, the same should be refunded to
him. The two sums may not be compensated against each
other because the appellant and the appellee are not debtors
and creditors of each other. With respect to the forest charges,
they are in the coffers of the government as taxes collected; the
government does not owe anything.
A claim for taxes is not such a debt, demand, contract or
judgement as is allowed to be set-off. No set-off is admissible
against demands for taxes levied for general or local
governmental purposes. Taxes grow out of a duty to, and are
the positive acts of the government, to the making and