Vidal de Roces v. Posadas G.R. No. 34937 March 13, 1933 Imperial, J.: Facts: 1.

Sometime in 1925, plaintiffs Concepcion Vidal de Roces and her husband, as well as one l!ira Richards, recei!ed as donation se!eral parcels of land from speran"a #ua"on. #he$ too% possession of the lands thereafter and li%ewise obtained the respecti!e transfer certificates. 2.#he donor died a $ear after without lea!in& an$ forced heir. 'n her will, which was admitted to probate, she be(ueathed to each of the donees the sum of )5,***. +fter the distribution of the estate but before the deli!er$ of their shares, the C'R ,appellee- ruled that plaintiffs as donees and le&atees should pa$ inheritance ta.es. #he plaintiffs paid the ta.es under protest. /. C'R filed a demurrer on &round that the facts alle&ed were not sufficient to constitute a cause of action. #he court sustained the demurrer and ordered the amendment of the complaint but the appellants failed to do so. 0ence, the trial court dismissed the action on &round that plaintiffs, herein appellants, did not reall$ ha!e a ri&ht of action. 1. )laintiffs ,appellant- contend that Sec. 151* of the +dministrati!e Code does not include donation inter vivos and if it does, it is unconstitutional, null and !oid for !iolatin& S C. / of the 2ones 3aw ,pro!idin& that no law shall embrace more than one sub4ect and that the sub4ect should be e.pressed in its titles 5 that the 3e&islature has no authorit$ to ta. donationinter vivos5 finall$, that said pro!ision !iolates the rule on uniformit$ of ta.ation. 5. C'R howe!er contends that the word 6all &ifts6 refer clearl$ to donationinter vivos and cited the doctrine in Tuason v. Posadas. Issue: Whether or not the donations should e su !ected to inheritance ta" 7 S. Sec. 151* of the +dministrati!e Code clearl$ refers to those donation inter vivos that ta%e effect immediatel$ or durin& the lifetime of the donor, but made in consideration of the death of the decedent. #hose donations not made in contemplation of the decedent6s death are not included as it would be e(ui!alent to imposin& a direct ta. on propert$ and not on its transmission. #he phrase 6all &ifts6 as held in Tuason v. Posadas refers to &ifts inter vivos as the$ are considered as ad!ances in anticipation of inheritance since the$ are made in consideration of death.