10 CASES
PEPSI-COLA BOTTLING COMPANY OF THE
NAPOCOR vs City of Cabanatuan GR No. 149110
ISSUE: WHETHER OR NOT, the court of appeals
gravely erred in not considering that an exercise of
police power through tax exemption should prevail
over the local government code.
RULING: NO, the court of appeals did not erred in
not considering that an exercise of police power
through tax exemption should prevail over the local
government code.
DOCTRINE: Lifeblood theory
“The theory behind the exercise of the power to tax
emanates from necessity; without taxes,
government cannot fulfill its mandate of promoting
the general welfare and well-being of the people.”
CIR vs Algue GR No. L-28896
ISSUE: WHETHER OR NOT the appeal of the private
respondent from the decision of the Collector of
Internal Revenue was made on time and in
accordance with law
RULING: YES, the appeal of the private respondent
from the decision of the Collector of the Internal
Revenue was made on time and in accordance with
law
DOCTRINE: SYMBIOTIC RELATIONSHIP
It is said that taxes are what we pay for civilized on
society. Without taxes, the government would be
paralyzed for lack of the move power to activate and
operate it. Hence, despite the natural reluctance to
surrender part of one's hard-earned income to the
taxing authorities, every person who is able to must
contribute his share in the running of the
government. The government for its part, is
expected to respond in the form of tangible and
intangible benefits intended to improve the lives of
the people and enhance their moral and material
values.
PHILIPPINES, INC. vs MUNICIPALITY OF TANAUAN,
LEYTE, THE MUNICIPAL MAYOR, ET AL.
ISSUE: WHETHER OR NOT is the section 2, Republic
Act No. 2264 an undue delegation of power,
confiscatory and oppressive
RULING: NO, the section 2, Republic Act No. 2264 is
not an undue delegation of power, confiscatory and
oppressive.
DOCTRINE: Principle of Double Taxation
Ordinances Nos. 23 and 27 do not constituted
taxation, in general, is not forbidden by our
fundamental law. It becomes obnoxious only
wherethe taxpayer is taxed twice for the benefit of
the same governmental entity or by the same
jurisdiction for the same purpose, but not in a case
where one tax is imposed by the State andthe other
by the city or municipality. The tax is not a
percentage tax as the volume capacity of the
taxpayer’s production of softdrinks is considered
solely for purposes of determine ng the tax rate on
the products but there is no set ratio between
volume of sales and amount of the tax. Nor can the
tax levied be treated as a specific tax. Softdrink is not
one of those specified articles.
Southern Luzon Drug vs DSWD GR No. 199669
ISSUE: WHETHER OR NOT The ca seriously erred on
a question of substance (concept) when it ruled that
the 20%, sales discount for senior citizens and pwds
is a valid exercise of police power. On the contrary, it
is an invalid exercise of the power of eminent
domain because it fails to provide just compensation
to the petitioner and other similarly situated
drugstores;
RULING: NO, the ca did not seriously erred on a
question of substance when it ruled that the 20%,
sales discount for senior citizens and pwds is a valid
exercise of police power. It is not an exercise of the
power of eminent domain and did not fail to provide
1
just compensation to the petitioner and other
similarly situated drugstores.
DOCTRINE:
The Supreme Court reiterated the doctrine that the
grant of benefits or privileges to special classes of
individuals, such as senior citizens and persons with
disability, through regulatory measures such as
discounts on purchases, is a valid exercise of the
State’s police power aimed at promoting their
welfare. Additionally, it emphasized the principle
that the State’s exercise of its police power is
presumed valid unless there is a clear and
unequivocal breach of constitutional limitations.
Tio vs Videogram GR No. L-75697
ISSUE: WHETHER OR NOT the tax imposed is harsh,
confiscatory, oppressive and/or in unlawful restraint
of trade in violation of the due process clause of the
Constitution.
RULING:
No, the tax imposed is not harsh, confiscatory,
oppressive and/or in unlawful restraint of trade and
not in violation of the due process clause of the
Constitution.
DOCTRINE:
It is inherent in the power to tax that a State be free
to select the subjects of taxation, and it has been
repeatedly held that "inequities which result from a
singling out of one particular class for taxation or
exemption infringe no constitutional limitation'
A tax does not cease to be valid merely because it
regulates, discourages, or even definitely deters the
activities taxed. The power to impose taxes is one so
unlimited in force and so searching in extent that the
courts scarcely venture to declare that it is subject
to any restrictions whatever, except such as rest in
the discretion of the authority which it exercises.
Lutz vs. Araneta GR No. L-7859
ISSUE: WHETHER OR NOT the legality of taxes
imposed by Commonwealth Act No. 567, otherwise
known as the Sugar Adjustment Act is valid.
RULING: YES, the legality of taxes imposed by
Commonwealth Act No. 567, otherwise known as
the Sugar Adjustment Act is valid
DOCTRINE: Taxation may be made as an implement
of the police power to promote the general welfare.
Progressive Development Corporation vs Quezon
City GR No. L-36081
ISSUE: WHETHER OR NOT the tax imposed by
respondent on gross receipts of stall rentals is
properly characterized as partaking of the nature of
an income tax or, alternatively, of a license fee.
RULING: YES, the tax imposed by respondent on
gross receipts of stall rentals is properly
characterized as partaking of the nature of an
income tax or, alternatively, of a license fee.
DOCTRINE:
If the generating of revenue is the primary purpose
and regulation is merely incidental, the imposition is
a tax: but if regulation is the primary purpose. the
fact that incidentally, revenue is also obtained does
not make the imposition a tax.
Caltex vs COA GR No. 92585
ISSUE: WHETHER OR NOT Caltex is entitled to
offsetting.
RULING: NO, Caltex is not entitled to offsetting.
DOCTRINE:
A taxpayer may not offset taxes due from the
claims that he may have against the government.
Confederation of Coconut Farmers Organization vs
Aq uino III GR No. 217965
2
ISSUE: WHETHER OR NOT, the president gravely Thus, E.O. No. 179 does not create a new special
abused his discretion when he arrogated unto fund but merely reiterates that revenues arising out
himself, without legislative authority, the power to of or in connection with the privatization of coconut
allocate, use and administer the subject coconut levy funds shall be deposited in the SAGF. An
levy funds and assets, which powers is exclusively automatic appropriation law is not necessarily
lodged with the PCA. unconstitutional for as long as there are clear
RULING: legislative parameters on how the amounts
appropriated are to be disbursed.
YES, the president gravely abused his discretion
when he arrogated unto himself, without legislative
authority, the power to allocate, use and administer
the subject coconut levy funds and assets, which
powers is exclusively lodged with the PCA.
DOCTRINE: (Principles) enjoyed immunity
pursuant to the principle of separation of powers.
They also point out that despite petitioner's claim
that the twin executive orders had infringed on the
powers of Congress, no member of Congress had
joined petitioner in the filing of the present suit...
the respondents assert that because members of
Congress have "a more direct and specific interest in
raising the questions being raised”the doctrine of
transcendental importance cannot be used to justify
petitioner's standing... when the Court, in COCOFED,
struck down P.D. No. 1468, as well as P.D. Nos. 755
and 961, the result was as if the aforementioned
laws did not exist at all... as declared in COCOFED,
P.D. No. 1234 should be considered the operative
law and that "coconut levies are special funds to be
remitted to the Treasury in the General Fund of the
State but treated as Special Accounts."
The said provision provides for two classification of
appropriation measures-general and special
appropriation. A general appropriation law is one
passed annually to provide for the financial
operations of the entire government during one
fiscal period, whereas a special appropriation is
designed for a specific purpose.
The revenue collected for a special purpose shall be
treated as a special fund to be used exclusively for
the stated purpose