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CIR vs. Algue Inc.

Taxes are the lifeblood of the government and so should be collected without
unnecessary hindrance, made in accordance with law.

Taxes are what we pay for civilization society. Without taxes, the government would be
paralyzed for lack of the motive power to activate and operate it

Pascual vs. Secretary of Public Works

It is a general rule that the legislature is without power to appropriate public revenue for
anything but a public purpose. It is the essential character of the direct object of the
expenditure which must determine its validity as justifying a tax, and not the magnitude
of the interest to be affected nor the degree to which the general advantage of the
community, and thus the public welfare, may be ultimately benefited by their promotion.

The test of the constitutionality of a statute requiring the use of public funds is whether
the statute is designed to promote the public interest, as opposed to the furtherance of
the advantage of individuals, although each advantage to individuals might incidentally
serve the public.

Planters Products, Inc. vs. Fertphil Corporation

In private suits, locus standi requires a litigant to be a "real party in interest" or party
who stands to be benefited or injured by the judgment in the suit. In public suits, there
is the right of the ordinary citizen to petition the courts to be freed from unlawful
government intrusion and illegal official action subject to the direct injury test or where
there must be personal and substantial interest in the case such that he has sustained
or will sustain direct injury as a result. Being a mere procedural technicality, it has also
been held that locus standi may be waived in the public interest such as cases of
transcendental importance or with far-reaching implications whether private or public
suit,

Police power is the power of the state to enact the legislation that may interfere with
personal liberty on property in order to promote general welfare. While, the power of
taxation is the power to levy taxes as to be used for public purpose. The main purpose
of police power is the regulation of a behavior or conduct, while taxation is revenue
generation.

Lutz vs. Araneta


The tax is levied with a regulatory purpose, i.e. to provide means for the rehabilitation
and stabilization of the threatened sugar industry. The act is primarily an exercise of
police power and is not a pure exercise of taxing power.

As sugar production is one of the great industries of the Philippines and its promotion,
protection and advancement redounds greatly to the general welfare, the legislature
found that the general welfare demanded that the industry should be stabilized, and
provided that the distribution of benefits had to sustain.

Tio vs. Videogram Regulatory Board

Taxation has been made the implement of the state's police power. The levy of the 30%
tax is for a public purpose. It was imposed primarily to answer the need for regulating
the video industry, particularly because of the rampant film piracy, the flagrant violation
of intellectual property rights, and the proliferation of pornographic video tapes. And
while it was also an objective of the DECREE to protect the movie industry, the tax
remains a valid imposition.

Pepsi-Cola Bottling Co. vs. Municipality of Tanauan, Leyte

Legislative powers may be delegated to local governments in respect of matters of local


concern. By necessary implication, the legislative power to create political corporations
for purposes of local self-government carries with it the power to confer on such local
governmental agencies the power to tax.

Moreover, double taxation, in general, is not forbidden by our fundamental law, so that
double taxation becomes obnoxious only where the 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 and the other by the
city or municipality.

Abakada Guro Party List vs. Ermita

It is not the law, but the revenue bill which is required by the Constitution to “originate
exclusively” in the House of Representatives, but Senate has the power not only to
propose amendments, but also to propose its own version even with respect to bills
which are required by the Constitution to originate in the House.

There is no undue delegation of legislative power but only of the discretion as to the
execution of a law. This is constitutionally permissible. Congress does not abdicate its
functions or unduly delegate power when it describes what job must be done, who must
do it, and what is the scope of his authority; in our complex economy that is frequently
the only way in which the legislative process can go forward.

Deutsche Bank AG Manila vs. CIR

The constitution provides for the adherence to the general principles of international law
as part of the law of the land (Article II, Section 2).Every treaty is binding upon the
parties, and obligations must be performed (Article 26, Vienna Convention on the Law
on Treaties). There is nothing in RMO 1-2000 indicating a deprivation of entitlement to a
tax treaty for failure to comply with the fifteen-day period. The denial of availment of tax
relief for the failure to apply within the prescribed period (under the administrative
issuance) would impair the value of the tax treaty. Also, the obligation to comply with the
tax treaty must take precedence over the objective of RMO 1-2000 because the non-
compliance with tax treaties would have negative implications on international affairs
and would discourage foreign investments.

Manila International Airport Authority vs. CA

MIAA's Airport Lands and Buildings are exempt from real estate tax imposed by local
governments.
First, MIAA is not a government-owned or controlled corporation but an instrumentality
of the National Government and thus exempt from local taxation. Second, the real
properties of MIAA are owned by the Republic of the Philippines and thus... exempt
from real estate tax.
There is no dispute that a government-owned or controlled corporation is not exempt
from real estate tax. However, MIAA is not a government-owned or controlled
corporation.
Since MIAA is neither a stock nor a non-stock corporation, MIAA does not qualify as a
government-owned or controlled corporation.
MIAA is a government instrumentality vested with corporate powers to perform
efficiently its governmental functions. MIAA is like any other government instrumentality,
the only difference is that MIAA is vested with corporate powers.
Another rule is that a tax exemption is strictly construed against the taxpayer claiming
the exemption. However, when Congress grants an exemption to a national government
instrumentality from local taxation, such exemption is construed liberally in favor of the
national... government instrumentality.

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