TAXATION LAW REVIEW

From the Lectures of Atty. Manuel P. Quibod, CPA 1

4 Manresa | SY 2020-2021

March 09, 2021 Part 1 of 3 | Carla Louise B. Bayquen

5. Decisions of the Central Board of Assessment Appeals in the
exercise of its appellate jurisdiction over cases involving the
assessment and taxation of real property originally decided by
the provincial or city board of assessment appeals (CTA en
banc)
This time from the CBAA the appellate jurisdiction is before the
CTA en banc directly, not division.
6. Decisions of the Secretary of Finance on customs cases
elevated to him automatically for review from decisions of the
Commissioner of Customs which are adverse to the
Government under Section 2315 of the Tariff and Customs Code
(now Section1128 of CMTA); (CTA div.)
Section 1128. Automatic Review by the Secretary of
Finance in Other Cases. – In cases not involving protest or
forfeiture, the commissioner shall automatically review any
decision by the district collector that is adverse to the
government. The records of the case shall be elevated to the
commissioner within five days from the promulgation of the
decision. The commissioner shall decide on the automatic
review within 30 days from receipt of the records, or within 10
days in the case of perishable goods. When new decision is
rendered within the prescribed period or when any decision
rendered by the commissioner is adverse to the government,
the records of the case under review shall be automatically
elevated within five days for the review of the secretary of
finance. The decision is should buy the secretary of finance,
whether or not the decision was rendered by the commissioner
within 30 days from the receipt of the records, or within 10 days
in the case of Persia but goods, shall be final upon the bureau.
automatically elevated within five days for review by the
secretary of finance. The decision should be the secretary of
finance whether or not the decision was rendered by the
commissioner within 30 days, within 10 days in the case of
perishable goods, from receipt of the records, shall be final upon
the bureau.
Formerly Section 2313.
Automatic Review in Forfeiture Cases
Claim filed – Collector – decision adverse to government
Automatic review (decision of the collector to the commissioner
– decision adverse to the government
Automatic review (decision of the commissioner) to the
Secretary of finance:
a.) decision is adverse to the government: final
b.) decision is adverse to taxpayer/importer: appeal to CTA
division – CTA en banc – SC
7. Decisions of the Secretary of Trade and Industry, in the case
of nonagricultural product, commodity or article, and the
Secretary of Agriculture in the case of agricultural product,
commodity or article, involving dumping and countervailing
duties under Section 301 and 302, respectively, of the Tariff and
Customs Code, and safeguard measures under R.A. No. 8800
where either party may appeal the decision to impose or not to
impose said duties.

Automatic Review by the Secretary of Finance in Other

Cases

In cases not involving protest or forfeiture (i.e. drawback, refund,

abatement)

Claim filed – Collector – decision adverse to government –

Automatic review (decision of collector) to the commissioner –

decision adverse to government –
Automatic review (decision of the commissioner) to the
Secretary of finance:
a.) decision is adverse to the government: final
b.) decision is adverse to taxpayer/importer: appeal to CTA
division – CTA en banc – SC
Section 1127. Automatic Review in Forfeiture Cases. – The
Commissioner shall automatically review any decision by the
district collector adverse to the government. The entire records
of Acacia be elevated within five days from the promotion of the
decision. The commissioner shall decide on the automatic
review within 30 days, or within 10 days in the case of
perishable goods, from receipt of the records. When no decision
is rendered within the prescribed period or when a decision
adverse to the government is rendered by the commissioner
involving goods with FOB or FCA value of 10 million pesos or
more, the records of the decision of the commissioner, or of the
district collector under review, as the case may be, shall be
To Impose or Not: Dumping Duty, Countervailing Duty &
Safeguard Measures
Dumping Duty
Imposition of additional duty. A special duty imposed when
imported articles are brought into the country and sold under its
normal value (market value).
As a result, it will injure locally produced products.
If agricultural, the Department of Agriculture will impose the
dumping, if non-agricultural, it will be the DTI, the DTI secretary
who will impose the dumping duty.
Countervailing Duty
A special duty imposed on imported articles which enjoys
subsidy or bounty in the country of origin. When it reaches the
Philippines it will compete with the locally produced products or
will injure the same because it enjoys subsidy or bounty in the
place of origin (manufactured/produced.

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 TAXATION LAW REVIEW
From the Lectures of Atty. Manuel P. Quibod, CPA
4 Manresa | SY 2020-2021
If agricultural, the Department of Agriculture will impose the
countervailing, if non-agricultural, it will be the DTI, the DTI
secretary who will impose the dumping duty.
There is countervailing to offset the seeming advantage of the
imported articles by reason of the subsidy or bounty it enjoys in
the country of origin.
Safeguard Measure
Imposed when there is neither dumping nor countervailing,
When there is a heavy surge in importation but does not result
to dumping nor countervailing, then the DTi/DA will impose a
safeguard measure so that it will not compete with the locally
produced products.
Current events update: DTI imposed safeguard measures to
motor vehicles which applies to all car manufacturers.
When the DTI Secretary decides to impose Dumping Duty,
Countervailing Duty & Safeguard Measures then the importer
can appeal.
Decision of the DTI/DA – to impose or no to impose DD/CD/SM
– Appeal to CTA division – Appeal to CTA en banc – Supreme
Court
*Note, prior to appealing there must be an MR filed.
TAX RELATED CRIMINAL OFFENSES
Exclusive original jurisdiction over all criminal offenses
arising from violations of the NIRC and other laws administered
by the Bureau of Internal Revenue or the Bureau of Customs:
were the principal amount of taxes and fees, exclusive of
charges and penalties, claim is 1 million pesos or more.
R.A. No. 9282 Section 7 b. Jurisdiction over cases involving
criminal offenses as herein provided:
1. Exclusive original jurisdiction over all criminal offenses arising
from violations of the National Internal Revenue Code or Tariff
and Customs Code and other laws administered by the Bureau
of Internal Revenue or the Bureau of Customs: Provided,
however, that offenses or felonies mentioned in this paragraph
where the principal amount of taxes and fees, exclusive of
charges and penalties, claimed is less than One million pesos
(P1,000,000.00) or where there is no specified amount claimed
shall be tried by the regular Courts and the jurisdiction of the
CTA shall be appellate. Any provision of law or the Rules of
Court to the contrary notwithstanding, the criminal action and the
corresponding civil action for the recovery of civil liability for
taxes and penalties shall at all times be simultaneously instituted
with, and jointly determined in the same proceeding by the CTA,
the filing of the criminal action being deemed to necessarily carry
with it the filing of the civil action, and no right to reserve the
filling of such civil action separately from the criminal action will
be recognized.
CTA division – CTA en banc – Supreme Court
If the amount involves less than 1 million or when
there is no specific amount claimed, jurisdiction is with
the regular courts.
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Amount of fees determine jurisdiction.
Note: CTA division hears the case like regular courts
because it is exercising exclusive original jurisdiction. It’s
just that instead of one. there are 3 justices. There is a
also a prosecutor and defense.
In the filing of a criminal case, there Is no need of a prior
assessment (only in tax collection).
Exclusive Appellate Jurisdiction in Criminal Offenses
R.A. No. 9282 Section 7 b.
2. Exclusive appellate jurisdiction in criminal offenses:
a. Over appeals from the judgments, resolutions or orders of the
Regional Trial Courts in tax cases originally decided by them, in
their respected territorial jurisdiction.
b. Over petitions for review of the judgments, resolutions or
orders of the Regional Trial Courts in the exercise of their
appellate jurisdiction over tax cases originally decided by the
Metropolitan Trial Courts, Municipal Trial Courts and Municipal
Circuit Trial Courts in their respective jurisdiction.
When the RTC decides in tax cases in the exercise of its
appellate jurisdiction, the appeal is to the CTA en banc.
That’s uniform. Whether it involves local taxes or tax
criminal offenses.
When the RTC decides in tax cases in the exercise of its
original jurisdiction, the appeal is to the CTA division
first.
Exclusive Original Jurisdiction Over Tax Collection Cases
R.A. No. 9282 Section 7 c. Jurisdiction over tax collection
cases as herein provided:
1. Exclusive original jurisdiction in tax collection cases involving
final and executory assessments for taxes, fees, charges and
penalties: Provided, however, That collection cases where the
principal amount of taxes and fees, exclusive of charges and
penalties, claimed is less than One million pesos
(P1,000,000.00) shall be tried by the proper Municipal Trial
Court, Metropolitan Trial Court and Regional Trial Court.
Tax collection cases amounting to 1M or more, the
jurisdiction is with the CTA division, not the regular
courts.
This will justify that you cannot pursue remedies without
prior assessment.
When you pursue judicial cases on collection cases for
an assessment that has become final and executory,
determine how much amount of taxes and fees involved.
If less than 1M, the jurisdiction is with the regular courts,
the MTC or RTC, depending on the jurisdictional amount.
Exclusive Appellate Jurisdiction in Tax Collection Cases
 TAXATION LAW REVIEW
From the Lectures of Atty. Manuel P. Quibod, CPA
4 Manresa | SY 2020-2021
R.A. No. 9282 Section 7 c. Jurisdiction over tax collection
cases as herein provided:
2. Exclusive appellate jurisdiction in tax collection cases:
a. Over appeals from the judgments, resolutions or orders of the
Regional Trial Courts in tax collection cases originally decided
by them, in their respective territorial jurisdiction.
b. Over petitions for review of the judgments, resolutions or
orders of the Regional Trial Courts in the Exercise of their
appellate jurisdiction over tax collection cases originally decided
by the Metropolitan Trial Courts, Municipal Trial Courts and
Municipal Circuit Trial Courts, in their respective jurisdiction.
Flow of Remedies in the Regular Courts
RTC – CTA division – CTA en banc – Supreme Court
MTC – RTC (appellate jurisdiction) – CTA en banc –
Supreme Court
March 09, 2021 Part 2 of 3 | MarisseAnne Coquilla
CTA en banc cases:
1. Local tax cases decided by RTC in its appellate
jurisdiction: Decisions, orders or resolutions of the RTC in
local taxes decided or resolved in the exercise of their
appellate jurisdiction;
2. Decisions of the Central Board of Assessment Appeals
(CBAA) in the exercise of its appellate jurisdiction: over
cases involving the assessment and taxation of real property
originally decide by the provincial or city board of
assessment appeals;
3. Decisions, orders or resolutions of the CTA division;
4. Criminal cases decided by RTC in its appellate
jurisdiction: Over petitions for review for the judgments,
resolutions or order of the RTC in the exercise of their
appellate jurisdiction over criminal tax cases originally
decided by MeTC, MTC and MCTC in their respective
jurisdiction.
5. Tax collection cases decided by the RTC in its appellate
jurisdiction: Over petitions for review for the judgments,
resolutions or order of the RTC in the exercise of their
appellate jurisdiction over tax collection cases originally
decided by MeTC, MTC and MCTC in their respective
jurisdiction.
SEC. 11. Who May Appeal; Mode of Appeal; Effect of
Appeal
WHO MAY APPEAL
Any party adversely affected by a decision, ruling or inaction
of
• the Commissioner of Internal Revenue,
• the Commissioner of Customs,
• the Secretary of Finance,
• the Secretary of Trade and Industry or
• the Secretary of Agriculture or
• the Central Board of Assessment Appeals or
• the Regional Trial Courts
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may file an appeal with the CTA within thirty (30) days after the
receipt of such decision or ruling or after the expiration of the
period fixed by law for action as referred to in Section 7(a)(2)
(RA 9282)
It does not necessarily follow that only the taxpayer appeals.
There are cases when it is the BIR that appeals.
MODE OF APPEAL
Appeal shall be made
• by filing a petition for review under a procedure analogous
to that provided for under Rule 42 of the 1997 Rules of Civil
Procedure
• with the CTA
• within thirty (30) days
Ø from the receipt of the decision or ruling or
Ø in the case of inaction as herein provided, from the expiration
of the period fixed by law to act thereon.
A Division of the CTA shall hear the appeal: Provided, however,
That with respect to decisions or rulings of the Central Board of
Assessment Appeals and the Regional Trial Court in the
exercise of its appellate jurisdiction appeal shall be made by
filing a petition for review under a procedure analogous to that
provided for under rule 43 of the 1997 Rules of Civil Procedure
with the CTA, which shall hear the case en banc.
• Rule 42 – if filed with the CTA division
• Rule 43 – if filed with the CTA en banc: decisions of the
CBAA and the RTCs regarding local tax cases in the
exercise of its appellate jurisdiction
MOTION FOR RECONSIDERATION REQUIREMENT
All other cases involving rulings, orders or decisions filed with
the CTA as provided for in Section 7 shall be raffled to its
Divisions. A party adversely affected by a ruling, order or
decision of a Division of the CTA may file a motion for
reconsideration of new trial before the same Division of the
CTA within fifteens (15) days from notice thereof: Provide,
however, That in criminal cases, the general rule applicable in
regular Courts on matters of prosecution and appeal shall
likewise apply.
REMINDER: File a Motion for Reconsideration from receipt of
the decision of the CTA, whether deciding by division or en banc,
before bringing the decision for further review/appeal.
EFFECT OF APPEAL
GR: No appeal taken to the CTA from the decision of
• the Commissioner of Internal Revenue or
• the Commissioner of Customs or
• the Regional Trial Court,
• provincial, city or municipal treasurer or
• the Secretary of Finance,
• the Secretary of Trade and Industry and Secretary of
Agriculture,
as the case may be shall suspend the payment, levy,
distraint, and/or sale of any property of the taxpayer for the
satisfaction of his tax liability as provided by existing law:
XPN: Provided, however, That when in the opinion of the
Court the collection by the aforementioned government
 TAXATION LAW REVIEW
From the Lectures of Atty. Manuel P. Quibod, CPA
4 Manresa | SY 2020-2021
agencies may jeopardize the interest of the Government
and/or the taxpayer the Court any stage of the proceeding
may
• suspend the said collection and
• require the taxpayer either
Ø to deposit the amount claimed or
Ø to file a surety bond for not more than double the
amount with the Court.
"In criminal and collection cases covered respectively by
Section 7(b) and (c) of this Act, the Government may directly
file the said cases with the CTA covering amounts within its
exclusive and original jurisdiction."
DEAN: As a rule, no injunction shall be issued for the principle
that taxes are the lifeblood of the government. Only in
exceptional cases.
SEC. 18. Appeal to the Court of Tax Appeals En Banc. - No
civil proceeding involving matter arising under the National
Internal Revenue Code, the Tariff and Customs Code or the
Local Government Code shall be maintained, except as herein
provided, until and unless an appeal has been previously filed
with the CTA and disposed of in accordance with the provisions
of this Act.
A party adversely affected by a resolution of a Division of the
CTA on a motion for reconsideration or new trial, may file a
petition for review with the CTA en banc.
REVIEW TO THE SUPREME COURT
SEC. 19. Review by Certiorari. - A party adversely affected by
a decision or ruling of the CTA en banc may file with the
Supreme Court a verified petition for review on certiorari
pursuant to Rule 45 of the 1997 Rules of Civil Procedure.
COLLECTION POWER OF CTA
Section 13. Distraint of Personal Property and/or Levy on
Real Property. - Upon the issuance of any ruling, order or
decision by the CTA favorable to the national government, the
CTA shall issue an order authorizing the Bureau of Internal
Revenue, through the Commissioner to
• seize and distraint any goods, chattels, or effects, and
the personal property, including stocks and other
securities, debts, credits, bank accounts, and interests
in and rights to personal property and/or
• levy the real property
of such persons in sufficient quantity to satisfy the tax or charge
together with any increment thereto incident to delinquency. This
remedy shall not be exclusive and shall not preclude the Court
from availing of other means under the Rules of Court.
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CTA JURISDICTION UNDER
RULE 65 – CERTIOTARI
INTERLOCUTORY COURT ORDERS ON TAX
CASES/TAX RELATED CASES
CTA, not the CA, has the power to rule on a Petition for
Certiorari assailing an interlocutory order of the RTC
relating to a local tax case. A certiorari petition questioning
an interlocutory order issued in a local tax case falls under
the jurisdiction of the CTA. (CE Casecnan Water and Energy
Co vs, Province of Nueva Ecija, GR No. 196278, June 17, 2015)
Dean: Aside from the exclusive appellate jurisdiction of the CTA,
and aside from its exclusive original jurisdiction of the CTA under
RA 9282, the SC made rulings that the CTA has also certiorari
powers under Rule 65.
When you are confronted with a tax case, and then there is an
ancillary resolution or order made by the court, and you want to
question that ancillary ruling or resolution by way of certiorari,
(because again remember under Rule 65, the remedy of appeal
is not available etc. etc.), the remedy is to go on a special civil
action under rule 65 which is certiorari. CTA (like the RTCs, CA
and the SC) has a judicial power. When you have a tax case and
there is a decision of a court, you want to have it reviewed by
way of certiorari, not with the CA but with the CTA because the
origin of that case is a tax case.
CTA has the jurisdiction to issue writs of certiorari or to
determine whether there has been grave abuse of
discretion amounting to lack or excess of jurisdiction on
the part of the RTC in issuing an interlocutory order in
cases falling within the CTAs exclusive appellate
jurisdiction. (City of Manila vs. Hon. Grecia-Cuerdo, GR No.
175723, February 04, 2014, SCRA 182)
Dean: Judge Cuerdo of the RTC of Manila issued an
interlocutory order. Where will you question his order for grave
abuse of discretion amounting to lack or in excess of
jurisdiction? CTA.
If the matter involved is a tax case and there is an order issued
by a local court and then you’d like to have that reviewed
because of GADALEJ, appeal is not in the CA but in the CTA.
Moreover, CTA is co-equal with CA.
BASIS:
While there is no express grant of such power, with respect to
the CTA, Section 1, Article VIII of the 1987 Constitution,
provides, nonetheless, that the judicial power shall be vested in
one Supreme Court and in such lower courts as may be
established by law and that judicial power includes the duty of
the courts of justice to settle actual controversies involving rights
which are legally demandable and enforceable and to determine
whether or not there has been GADALEJ on the part of any
branch or instrumentality of the government.
The CTA, by constitutional mandate, is vested with jurisdiction
to issue writs of certiorari in these cases.
DOJ RESOLUTION ON TAX OFFENSES: CTA-
CERTIORARI
 TAXATION LAW REVIEW
From the Lectures of Atty. Manuel P. Quibod, CPA
4 Manresa | SY 2020-2021
The CA’s original jurisdiction over a petition for certiorari
assailing the DOJ resolution in a preliminary investigation
involving tax and tariff offenses was necessarily transferred to
the CTA pursuant to Section 7 of RA 9282, and such petition
shall be governed by Rule 65 of the ROC, as amended.
Accordingly, it is the CTA, not the CA, which has jurisdiction over
the petition for certiorari assailing the DOJ resolution of
dismissal of the BOC’s complaint affidavit against the
respondents for the violation of the Tariff and Customs Code of
the Philippines. (BOC vs Devanadera, GR No. 193253,
September 8, 2015)
Dean: Again, if the origin is a tax case, and you want to assail
any resolution or order having been rendered with GADALEJ,
then the certiorari is to the CTA, not to the CA. The basis is in
Sec.7 of RA 9282.
CTA JURISDICTION ON ALL TAX CASES AND
MATTERS RELATED THERETO EVEN IF TAXPAYER
IS UNDER CORPORATE REHAB (Steel Corp vs BOC,
GR No. 220502, February 12, 2018)
ISSUE: Whether a corporation placed under corporate
rehabilitation can avail the benefits of Section 19 of RA No.
10142, which issue is cognizable by the RTC and whose
decision may be appealed to the CA or the SC and not to
any other court like the CTA.
Section 19. Waiver of taxes and Fees Due to the National
Government and to Local Government Units (LGUs). - Upon
issuance of the Commencement Order by the court, and until
the approval of the Rehabilitation Plan or dismissal of the
petition, whichever is earlier, the imposition of all taxes and
fees including penalties, interests and charges thereof due
to the national government or to LGUs shall be considered
waived, in furtherance of the objectives of rehabilitation.
RULING: CTA has exclusive appellate jurisdiction on the issue
on the waiver of taxes under Section 19 of FRIA including
injunctive relief.
The Court of Tax Appeals has undoubted jurisdiction to pass
upon the constitutionality or validity of a tax law or regulation
when raised by the taxpayer as a defense in disputing or
contesting an assessment or claiming a refund. It is only in the
lawful exercise of its power to pass upon all matters brought
before it (Section 7 of Republic Act No. 1125, as amended).
Within the judicial system, the law intends the Court of Tax
Appeals to have exclusive jurisdiction to resolve all tax
problems. Petitions for writs of certiorari against the acts and
omissions of the said quasi-judicial agencies should, thus, be
filed before the Court of Tax Appeals.
Dean: Since this is a tax case, a waiver of taxes under Sec. 19
of the FRIA, then the remedy is to appeal it to the CTA. This
includes an action for an injunctive relief, (ex. to restrain BIR or
BOC to collect). You cannot find this in the law but in the
jurisprudence.
1
BDO, et. al vs. RP, CIR, et. al, GR No. 198756, August 16, 2016 (en
banc) J. Leonen
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March 9, 2021 Part 3 of 3 | Cavin Jhon M. Cabarlo
EXTENT OF THE CTA JURISDICTION
RA 1125, as amended by RA 9282
Section 7. Jurisdiction. - The Court of Tax Appeals shall
exercise exclusive appellate jurisdiction to review by appeal, as
herein provided.
(1) Decisions of the Collector of Internal Revenue in cases
involving disputed assessments, refunds of internal revenue
taxes, fees or other charges, penalties imposed in relation
thereto, or other matters arising under the National Internal
Revenue Code or other law or part of law administered by the
Bureau of Internal Revenue;
(2) Decisions of the Commissioner of Customs in cases
involving liability for customs duties, fees or other money
charges; seizure, detention or release of property affected fines,
forfeitures or other penalties imposed in relation thereto; or
other matters arising under the Customs Law or other law or
part of law administered by the Bureau of Customs; and
(3) Decisions of provincial or city Boards of Assessment
Appeals in cases involving the assessment and taxation of real
property or other matters arising under the Assessment Law,
including rules and regulations relative thereto.
1. Exclusive jurisdiction to resolve all tax-related
issues.
2. Pass upon the constitutionality or validity of a tax law
or regulation when raised by the taxpayer as a defense
in disputing or contesting an assessment or claiming a
refund.
It is only in the lawful exercise of its power to pass upon
all matters brought before it, as sanctioned by Section
7 of Republic Act No. 1125, as amended.
3. Take cognizance of cases directly challenging the
constitutionality or validity of a tax law or regulation or
administrative issuance (revenue orders, revenue
memorandum circulars.
4. Except for local taxes, appeals from the decisions
of quasi-judicial agencies (Commissioner of Internal
Revenue, Commissioner of Customs, Secretary of
Finance, Central Board of Assessment Appeals,
Secretary of Trade and Industry) on tax-related
problems must be brought exclusively to the CTA.
5. Within the judicial system, the law intends the CTA to
have exclusive jurisdiction to resolve all tax
problems. Petitions for writ of certiorari against the acts
and omissions of the said quasi-judicial agencies
should, thus, be filed before the CTA1.
6. RA 9282, a special and later law than Batas Pambansa
Blg. 129, provides an exception to the original
 TAXATION LAW REVIEW
From the Lectures of Atty. Manuel P. Quibod, CPA 6
4 Manresa | SY 2020-2021

jurisdiction of the Regional Trial Court over actions

questioning the constitutionality or validity of tax laws
or regulations. Except for local tax cases, actions
directly challenging the constitutionality or validity
of a tax law or regulation or administrative
issuance may be filed directly before the CTA.

7. With respect to administrative issuances (revenue

orders, revenue memorandum circulars, or rulings),
these are issued by the CIR under its power to make
rulings or opinions in connection with the
implementation of the provisions of internal revenue
laws. Tax rulings, on the other hand, are official
positions of the BIR on inquiries of taxpayers who
request clarification on certain provisions of the NIRC,
other tax laws, or their implementing regulations.
Hence, the determination of the validity of these
issuances clearly falls within the exclusive
appellate jurisdiction of the CTA under Section 7 (1)
of RA 1125, as amended, subject to prior review by the
Secretary of Finance, as required under RA 8424.

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