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MALCOLM, J.:
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PHILIPPINE REPORTS ANNOTATED VOLUME 056 19/02/2019, 11(30 PM
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PHILIPPINE REPORTS ANNOTATED VOLUME 056 19/02/2019, 11(30 PM
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"2. The trial court erred in reading into the law certain
exceptions and distinctions not warranted by its
clear and unequivocal provisions.
"3. The trial court erred in assuming that the proceeds
of the life insurance policy in question represented
a net profit to the plaintiff when, as a matter of
fact, it merely represented an indemnity for the loss
suffered by it thru the death of its manager, the
insured.
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PHILIPPINE REPORTS ANNOTATED VOLUME 056 19/02/2019, 11(30 PM
The Income Tax Law for the Philippines is Act No. 2833, as
amended. It is divided into four chapters: Chapter I On
Individuals, Chapter II On Corporations, Chapter III
General Administrative Provisions, and Chapter IV
General Provisions. In Chapter I On Individuals, is to be
found section 4 which provides that, "The following incomes
shall be exempt f rom the provisions of this law: (et) The
proceeds of life insurance policies paid to beneficiaries upon
the death of the insured * * *." Section 10, as amended, in
Chapter II On Corporations, provides that, "There shall be
levied, assessed, collected, and paid annually upon the total
net income received in the preceding calendar year f rom
all sources by every corporation * * * a tax of three per
centum upon such income * * *." Section 11 in the same
chapter, provides the exemptions under the law, but
neither here nor in any other section is reference made to
the provisions of section 4 in Chapter I.
Under the view we take of the case, it is -sufficient f or
our purposes to direct attention to the anomalous and
vague condition of the law. It is certain that the proceeds of
lif e insurance policies paid to individual beneficiaries upon
the death of the insured are exempt. It is not so certain
that the proceeds of life insurance policies paid to corporate
beneficiaries upon the death of the e insured are likewise
exempt. But at least, it may be said that the law is indefi-
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PHILIPPINE REPORTS ANNOTATED VOLUME 056 19/02/2019, 11(30 PM
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PHILIPPINE REPORTS ANNOTATED VOLUME 056 19/02/2019, 11(30 PM
Judgment reversed.
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