Tax 2 Page 27

TAXATION II (Carag) Reviewer Ann, Dana, David, Jenin and Sandy
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TAXATION II

(5) Issuance of Final Deed to Purchaser for
Failure to Redeem
Sec. 262, LGC
SEC. 262. Final Deed to Purchaser. - In case the owner or person
having legal interest therein fails to redeem the delinquent
property as provided herein, the local treasurer shall execute a
deed conveying to the purchaser said property, free from lien of
the delinquent tax, interest due thereon and expenses of sale. The
deed shall briefly state the proceedings upon which the validity
of the sale rests.
Art. 353, IRR of LGC
ARTICLE 353. Final Deed to Purchaser. In case the owner or
person having legal interest therein fails to redeem the
delinquent property as provided herein, the local treasurer shall
execute a deed conveying to the purchaser said property, free
from lien of the delinquent tax, interest due thereon and
expenses of sale. The deed shall briefly state the proceedings
upon which the validity of the sale rests.
Issuance of Final Deed to Purchaser
When: upon failure of the delinquent taxpayer to redeem
the property within 1 year from the date of sale.

Redemption of Real Property (Sec. 261)
1. Within 1 year from the date of the sale, the owner of the
delinquent real property, or person having legal interest or
his representative, shall have the right to redeem the
property upon payment to the local treasurer of the
following:
a. amount of delinquent tax
b. interest thereon
c. expense of sale from date of delinquency to date
of sale
d. interest of not more than 2% per month on the
purchase price from the date of sale to date of
redemption
2. A certificate of redemption shall be issued, and the
certificate of sale issued to the purchaser shall be
invalidated.

ii. Judicial Action
Sec. 266, LGC
SEC. 266. Collection of Real Property Tax Through the Courts. - The
local government unit concerned may enforce the collection of
the basic real property tax or any other tax levied under this Title
by civil action in any court of competent jurisdiction. The civil
action shall be filed by the local treasurer within the period
prescribed in Section 270 of this Code.
ARTICLE 357. Collection of Real Property Tax Through the
Courts. The delinquent basic real property tax or any other tax
levied under this Rule shall constitute a lawful indebtedness of
the taxpayer to the LGU. Collection of such indebtedness can be
enforced thru civil action in any court of competent jurisdiction,
as follows:
(a) The provincial or city treasurer, or municipal treasurer of a
municipality of MMA shall furnish the provincial attorney or city
or municipal legal officer a certified statement of delinquency
who, within fifteen (15) days after receipt, shall file the civil
action in the name of the province, city, or municipality in the
proper court of competent jurisdiction. The jurisdiction of the
court is determined by the amount sought to be recovered
exclusive of interests and costs. Thus, where the delinquent tax
due does not exceed Ten Thousand Pesos (P10,000.00), the
competent court is the municipal or city trial court, and where
the amount due is in excess of Ten Thousand Pesos (P10,000.00),
the proper court is the regional trial court.
(b) Where cognizable in an inferior court, the action must be filed
in the municipality or city where the delinquent property is
located. Where the regional trial court has jurisdiction, the
plaintiff LGU shall file the complaint in the city or province where
the property is situated.
(c) In both cases, that is, where the claim is either cognizable by
an inferior court or by the regional trial court, the provincial or
city treasurer shall furnish the provincial attorney or the city or
municipal legal officer concerned the exact address of the
defendant where he may be served with summons.

Judicial action (civil action) under Sec. 266 of LGC- filed by
the local treasurer within 5 or 10 years as provided for in
Sec. 270 of the LGC.
Jurisdiction: regular courts since CTA has no jurisdiction
thereover.

(d) Resale of Real Estate Taken for Taxes, Fees or
Charges
Sec. 264, LGC
SEC. 264. Resale of Real Estate Taken for Taxes, Fees, or Charges. -
The sanggunian concerned may, by ordinance duly approved, and
upon notice of not less than twenty (20) days, sell and dispose of
the real property acquired under the preceding section at public
auction. The proceeds of the sale shall accrue to the general fund
of the local government unit concerned.
RTICLE 355. Resale of Real Estate Taken for Taxes, Fees, or
Charges. The sanggunian concerned may, by a duly approved
ordinance, and upon notice of not less than twenty (20) days, sell
and dispose of the real property acquired under the preceding
Article at public auction. The proceeds of the sale shall accrue to
the general fund of the LGU concerned.

When LGU may purchase Real Property Advertised For
Sale:
1. if there is no bidder; or
2. if the highest bid is for an amount insufficient to pay the
real property tax, fees, charges, surcharges, interests or
penalties (Sec. 263, LGC)

(e) Further Levy until full payment of amount due
Sec. 265, LGC
SEC. 265. Further Distraint or Levy. - Levy may be repeated if
necessary until the full amount due, including all expenses, is
collected.
ARTICLE 356. Further Distraint or Levy. Levy may be repeated
if necessary on the same property subject to tax until the full
amount due, including all expenses, is collected.

NOTE: Unlike other local taxes where administrative
remedies to enforce collection include distraint of personal

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property and levy upon real property, Sec. 256 of the LGC
expressly provides that in case of RPT, administrative
action may only be thru levy on real property.

(f) Special rules on actions involving real property
i. Deposit required for actions assailing
validity of tax sale
Sec. 267, LGC
SEC. 267. Action Assailing Validity of Tax Sale. - No court shall
entertain any action assailing the validity of any sale at public
auction of real property or rights therein under this Title until the
taxpayer shall have deposited with the court the amount for
which the real property was sold, together with interest of two
percent (2%) per month from the date of sale to the time of the
institution of the action. The amount so deposited shall be paid to
the purchaser at the auction sale if the deed is declared invalid
but it shall be returned to the depositor if the action fails. Neither
shall any court declare a sale at public auction invalid by reason
of irregularities or informalities in the proceedings unless the
substantive rights of the delinquent owner of the real property or
the person having legal interest therein have been impaired.
ARTICLE 358. Action Assailing Validity of Tax Sale. (a) No
court shall entertain any action assailing the validity of any sale
at public auction of real property or rights therein under this
Rule until the taxpayer shall have deposited with the court the
amount for which the real property was sold, together with
interest of two percent (2%) per month from the date of sale to
the time of the institution of the action. The amount so deposited
shall be paid to the purchaser at the auction sale if the deed is
declared invalid but it shall be returned to the depositor if the
action fails.
(b) No court shall declare a sale at public auction invalid by
reason of irregularities or informalities in the proceedings unless
the substantive rights of the delinquent owner of the real
property or the person having legal interest therein have been
impaired.

ii. Award of property subject of court action
upon payment of delinquent taxes
Sec. 268, LGC
SEC. 268. Payment of Delinquent Taxes on Property Subject of
Controversy. - In any action involving the ownership or
possession of, or succession to, real property, the court may,
motu propio or upon representation of the provincial, city, or
municipal treasurer or his deputy, award such ownership,
possession, or succession to any party to the action upon
payment to the court of the taxes with interest due on the
property and all other costs that may have accrued, subject to the
final outcome of the action.
ARTICLE 359. Payment of Delinquent Taxes on Property Subject
of Controversy. In any action involving the ownership or
possession of, or succession to, real property the court may, motu
proprio or upon representation of the provincial, city, or
municipal treasurer or their respective deputies, award such
ownership, possession, or succession to any party to the action
upon payment to the court of the taxes with interests due to the
property and all other costs that may have accrued, subject to the
final outcome of the action.

E. Taxpayers Remedies
1. Contesting an Assessment of Value of Real
Property

Protest by: Owner or person legally interested in the
property who is not satisfied with the action of the
assessor in the assessment of his property
How: Appeal to LBAA (then the CBAA, if necessary)
When : within 60 days from the date of receipt of the
written notice of assessment
What: petition under oath, in the form prescribed, together
with the copies of the tax declaration and affidavits or
documents.
Effect of Appeal on Payment of RPT: does not suspend
collection for payment of the RPT, subject, however to
adjustments should it be decided that another amount
should be paid.

(a) Appeal to the Local Board of Assessment
Appeals
Sec. 226, LGC
SEC. 226. Local Board of Assessment Appeals. - Any owner or
person having legal interest in the property who is not satisfied
with the action of the provincial, city or municipal assessor in the
assessment of his property may, within sixty (60) days from the
date of receipt of the written notice of assessment, appeal to the
Board of Assessment appeals of the province or city by filing a
petition under oath in the form prescribed for the purpose,
together with copies of the tax declarations and such affidavits or
documents submitted in support of the appeal.
ARTICLE 317. Local Board of Assessment Appeals. (a) Any
property owner or person having legal interest or claim in the
property who is not satisfied with the assessment of his property
made by the provincial, city, or municipal assessor pursuant to
the provisions of this Rule may, within sixty (60) days from the
date of receipt of the written notice of assessment, appeal to local
board of assessment appeals of the province or city where the
subject property is situated by filing a petition under oath in the
standard form prescribed therefor, together with copies of the
tax declaration and such affidavits or documents in support of the
appeal.
(b) In the case of municipalities within MMA, the appeals may be
filed with the municipal board of assessment appeals of each
municipality as provided in Article 318 of this Rule.

(i) Action by LBAA
Sec. 229, LGC
SEC. 229. Action by the Local Board of Assessment appeals. - (a)
The Board shall decide the appeal within one hundred twenty
(120) days from the date of receipt of such appeal. The Board,
after hearing, shall render its decision based on substantial
evidence or such relevant evidence on record as a reasonable
mind might accept as adequate to support the conclusion.
(b) In the exercise of its appellate jurisdiction, the Board shall
have the power to summon witnesses, administer oaths, conduct
ocular inspection, take depositions, and issue subpoena and
subpoena duces tecum. The proceedings of the Board shall be
conducted solely for the purpose of ascertaining the facts without
necessarily adhering to technical rules applicable in judicial
proceedings.
(c) The secretary of the Board shall furnish the owner of the
property or the person having legal interest therein and the

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provincial or city assessor with a copy of the decision of the
Board. In case the provincial or city assessor concurs in the
revision or the assessment, it shall be his duty to notify the owner
of the property or the person having legal interest therein of such
fact using the form prescribed for the purpose. The owner of the
property or the person having legal interest therein or the
assessor who is not satisfied with the decision of the Board, may,
within thirty (30) days after receipt of the decision of said Board,
appeal to the Central Board of Assessment appeals, as herein
provided. The decision of the Central Board shall be final and
executor.
ARTICLE 320. Action by the Local Board of Assessment Appeals.
(a) From the date of receipt of an appeal, the local board of
assessment appeals shall, on the basis of substantial evidence or
such relevant evidence on record adequately acceptable to
support a conclusion, decide such appeal within one hundred
twenty (120) days.
(b) In the exercise of its appellate jurisdiction, the board shall
have the power to summon witnesses, administer oaths, conduct
ocular inspection, take depositions, and issue subpoena and
subpoena duces tecum. The proceedings of the board shall be
conducted solely for the purpose of ascertaining the facts without
necessarily adhering to technical rules applicable in judicial
proceedings.
(c) The secretary of the board shall furnish the owner of the
property or the person having legal interest therein and the
provincial or city assessor or municipal assessor within MMA
with a copy of the decision of the board. In case the provincial or
city assessor or municipal assessor within MMA concurs with the
revision or the assessment, it shall be his duty to notify the owner
of the property or the person having legal interest therein of such
fact using the form prescribed for the purpose.
The owner of the property or the person having legal interest
therein or the assessor who is not satisfied with the decision of
the board may, within thirty (30) days after receipt of the
decision of the board, appeal to the Central Board of Assessment
Appeals as herein provided. The decision of the Central Board
shall be final and executory.

Callanta v. Office of the Ombudsman
City Assessor reassessed the values of properties after notice of
assessment was sent to property owners. The reassessment was
made without the authority of the LBAA and resulted in the
reduction of assessed values.
Held: City assessor did not have the power to reassess the subject
properties. Once the notice of assessment is sent to property
owners, the City Assessors office is done and whatever
complaints owners have with the assessment must be made to the
LBAA pursuant to the LGC.

(b) Appeal to the Central Board of Assessment
Appeals (CBAA)
Sec. 230, LGC
SEC. 230. Central Board of Assessment appeals.- The Central Board
of Assessment appeals shall be composed of a chairman and two
(2) members to be appointed by the President, who shall serve
for a term of seven (7) years, without reappointment. Of those
first appointed, the chairman shall hold office for seven (7) years,
one member for five (5) years, and the other member for three
(3) years. Appointment to any vacancy shall be only for the
unexpired portion of the term of the predecessor. In no case shall
any member be appointed or designated in a temporary or acting
capacity. The chairman and the members of the Board shall be
Filipino citizens, at least forty (40) years old at the time of their
appointment, and members of the Bar or Certified Public
Accountants for at least ten (10) years immediately preceding
their appointment. The chairman of the Board of Assessment
appeals shall have the salary grade equivalent to the rank of
Director III under the Salary Standardization Law exclusive of
allowances and other emoluments. The members of the Board
shall have the salary grade equivalent to the rank of Director II
under the Salary Standardization Law exclusive of allowances
and other emoluments. The Board shall have appellate
jurisdiction over all assessment cases decided by the Local Board
of Assessment appeals.
There shall be Hearing Officers to be appointed by the Central
Board of Assessment appeals pursuant to civil service laws, rules
and regulations, one each for Luzon, Visayas and Mindanao, who
shall hold office in Manila, Cebu City and Cagayan de Oro City,
respectively, and who shall serve for a term of six (6) years,
without reappointment until their successors have been
appointed and qualified. The Hearing Officers shall have the same
qualifications as that of the Judges of the Municipal Trial Courts.
The Hearing Officers shall each have the salary grade equivalent
to the rank of Director I under the Salary Standardization Law
exclusive of allowances and other emoluments. The Hearing
Officers shall try and receive evidences on the appealed
assessment cases as may be directed by the Board.
The Central Board Assessment appeals, in the performance of its
powers and duties, may establish and organize staffs, offices,
units, prescribe the titles, functions and duties of their members
and adopt its own rules and regulations. Unless otherwise
provided by law, the annual appropriations for the Central Board
of Assessment appeals shall be included in the annual budget of
the Department of Finance in the corresponding General
Appropriations Act.
ARTICLE 321. Central Board of Assessment Appeals. The
Central Board shall be composed of a chairman and two (2)
members to be appointed by the President, who shall serve for a
term of seven (7) years, without reappointment. Of those first
appointed, the chairman shall hold office for seven (7) years, one
member for five (5) years, and the other member of three (3)
years. Appointment to any vacancy shall be only for the
capacity.
The chairman and the members of the Central Board shall be
Filipino citizens, at least forty(40) years old at the time of their
their appointment. The chairman of the Central Board shall have
the salary grade equivalent to the rank of Director III under the
Salary Standardization Law exclusive of allowances and other
emoluments. The members of the Central Board shall have the
salary grade equivalent to the rank of Director II under the Salary
Standardization Law exclusive of allowances and other
emoluments. The Central Board shall have appellate jurisdiction
over all assessment cases decided by the local board and
assessment appeals.
There shall be hearing officers to be appointed by the Central
Board pursuant to civil service law, rules and regulations, one
each of Luzon, Visayas, and Mindanao, who shall hold office in the
City of Manila, Cebu City, and Cagayan de Oro City, respectively,
and who shall serve for a term of six (6) years, without
reappointment until their successors shall have been appointed
and qualified. The hearing officers shall have the same
qualifications as those of the Judges of the Municipal Trial Courts.

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The hearing officers shall each have a salary grade equivalent to
the rank of Director I under the Salary Standardization Law
exclusive of allowances and other emoluments. The hearing
officers shall try and receive evidences on the appealed
assessment cases as may be directed by the Central Board.
The Central Board, in the performance of its powers and duties,
may establish and organize staffs, offices, or units, prescribe the
titles, functions and duties of their members, and adopt its own
rules and regulations.
Unless otherwise provided by law, the annual appropriations for
the Central Board shall be included in the annual budget of DOF.

(c) Effect of Appeal on Payment of RPT
Sec. 231, LGC
SEC. 231. Effect of appeal on the Payment of Real Property Tax. -
appeal on assessments of real property made under the
provisions of this Code shall, in no case, suspend the collection of
the corresponding realty taxes on the property involved as
assessed by the provincial or city assessor, without prejudice to
subsequent adjustment depending upon the final outcome of the
appeal.
ARTICLE 322. Effect of Appeal on the Payment of Real Property
Tax. Appeals on assessments of real property made under the
provisions of this Rule shall, in no case, suspend the collection of
the corresponding real property taxes on the property involved
as assessed by the provincial or city assessor, or the municipal
assessor within MMA, without prejudice to subsequent
adjustment depending upon the final outcome of the appeal.

2. Payment of Real Property Tax under
Protest

Sec. 252, LGC
SEC. 252. Payment Under Protest. - (a) No protest shall be
entertained unless the taxpayer first pays the tax. There shall be
annotated on the tax receipts the words "paid under protest". The
protest in writing must be filed within thirty (30) days from
payment of the tax to the provincial, city treasurer or municipal
treasurer, in the case of a municipality within Metropolitan
Manila Area, who shall decide the protest within sixty (60) days
from receipt.
(b) The tax or a portion thereof paid under protest, shall be held
in trust by the treasurer concerned.
(c) In the event that the protest is finally decided in favor of the
taxpayer, the amount or portion of the tax protested shall be
refunded to the protestant, or applied as tax credit against his
existing or future tax liability.
(d) In the event that the protest is denied or upon the lapse of the
sixty day period prescribed in subparagraph (a), the taxpayer
may avail of the remedies as provided for in Chapter 3, Title II,
Book II of this Code.
ARTICLE 343. Payment Under Protest. (a) No protest shall be
entertained unless the taxpayer first pays the tax. There shall be
annotated on the tax receipts the words paid under protest. The
protest in writing must be filed within thirty (30) days from
payment of the tax to the provincial or city treasurer, or
municipal treasurer, in the case of a municipality within MMA,
who shall decide the protest within sixty (60) days from receipt.
(b) The tax or a portion thereof paid under protest shall be held
in trust by the local treasurer concerned. Fifty percent (50%) of
the tax paid under protest shall, however, be distributed in
accordance with the provisions of this Rule on the distribution of
proceeds.
(c) In the event that the protest is finally decided in favor of the
taxpayer, the amount or portion of the tax protested shall be
refunded to the protestant, or applied as tax credit against his
existing or future tax liability.
(d) In the event that the protest is denied or upon the lapse of the
sixty-day period prescribed in paragraph (a) hereof, the taxpayer
may avail of the remedies provided in Articles 317 and 320 of
this Rule.

Procedure:
1. Pay the tax under protest
2. File written protest with Local Treasurer )within 30
days from payment of tax)
3. Treasurer decides (within 60 days from receipt of
protest)
4. If approved, the amount shall be refunded or applied as
tax credit;
If denied, appeal to LBAA (in case of denial or inaction of
the treasurer, after the lapse of 60 days)
5. Appeal with the CBAA (within 30 days from receipt of
adverse decision by LBAA)

Sec. 252 requires taxpayer to first pay the tax. PAYMENT
UNDER PROTEST. The protest may be filed within 30 days
from the payment of the tax. Thereafter, the words paid
under protest shall be annotated on the tax receipt. The
Tax or portion thereof paid under protest shall be held in
trust by the treasurer concerned.

Protest contemplated in Sec. 252 is needed where there is
a question as to the reasonableness of the amount
assessed, NOT where the question raised is on the very
authority and power of the assessor to impose the
assessment and of the treasurer to collect the tax (Ty. v.
Trampe)

No MR for the adverse decision of the Local Assessor or
Treasurer- the remedy is to appeal to the LBAA
The last action of the local assessor on a particular
assessment shall be the notice of assessment; it is this last
action which gives the owner of the property the right to
appeal to the LBAA. The procedure likewise does not
permit the property owner the remedy of filing an MR
before the local assessor (FELS Energy v. Province of
Batangas)

(a) File protest with local treasurer

(b) Appeal to the LBAA
Sec. 226, LGC
SEC. 226. Local Board of Assessment Appeals. - Any owner or
person having legal interest in the property who is not satisfied
with the action of the provincial, city or municipal assessor in the
assessment of his property may, within sixty (60) days from the
date of receipt of the written notice of assessment, appeal to the
Board of Assessment appeals of the province or city by filing a
petition under oath in the form prescribed for the purpose,
together with copies of the tax declarations and such affidavits or

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documents submitted in support of the appeal.
ARTICLE 317. Local Board of Assessment Appeals. (a) Any
property owner or person having legal interest or claim in the
property who is not satisfied with the assessment of his property
made by the provincial, city, or municipal assessor pursuant to
the provisions of this Rule may, within sixty (60) days from the
date of receipt of the written notice of assessment, appeal to local
board of assessment appeals of the province or city where the
subject property is situated by filing a petition under oath in the
standard form prescribed therefor, together with copies of the
tax declaration and such affidavits or documents in support of the
appeal.
(b) In the case of municipalities within MMA, the appeals may be
filed with the municipal board of assessment appeals of each
municipality as provided in Article 318 of this Rule.

(c) Appeal to the CBAA
Sec. 230, LGC
SEC. 230. Central Board of Assessment appeals.- The Central Board
of Assessment appeals shall be composed of a chairman and two
(2) members to be appointed by the President, who shall serve
for a term of seven (7) years, without reappointment. Of those
first appointed, the chairman shall hold office for seven (7) years,
one member for five (5) years, and the other member for three
(3) years. Appointment to any vacancy shall be only for the
capacity. The chairman and the members of the Board shall be
Filipino citizens, at least forty (40) years old at the time of their
their appointment. The chairman of the Board of Assessment
appeals shall have the salary grade equivalent to the rank of
Director III under the Salary Standardization Law exclusive of
allowances and other emoluments. The members of the Board
shall have the salary grade equivalent to the rank of Director II
and other emoluments. The Board shall have appellate
jurisdiction over all assessment cases decided by the Local Board
of Assessment appeals.
There shall be Hearing Officers to be appointed by the Central
Board of Assessment appeals pursuant to civil service laws, rules
and regulations, one each for Luzon, Visayas and Mindanao, who
shall hold office in Manila, Cebu City and Cagayan de Oro City,
respectively, and who shall serve for a term of six (6) years,
without reappointment until their successors have been
appointed and qualified. The Hearing Officers shall have the same
qualifications as that of the Judges of the Municipal Trial Courts.
The Hearing Officers shall each have the salary grade equivalent
to the rank of Director I under the Salary Standardization Law
exclusive of allowances and other emoluments. The Hearing
Officers shall try and receive evidences on the appealed
assessment cases as may be directed by the Board.
The Central Board Assessment appeals, in the performance of its
powers and duties, may establish and organize staffs, offices,
units, prescribe the titles, functions and duties of their members
and adopt its own rules and regulations. Unless otherwise
provided by law, the annual appropriations for the Central Board
of Assessment appeals shall be included in the annual budget of
the Department of Finance in the corresponding General
Appropriations Act.
ARTICLE 321. Central Board of Assessment Appeals. The
Central Board shall be composed of a chairman and two (2)
members to be appointed by the President, who shall serve for a
term of seven (7) years, without reappointment. Of those first
appointed, the chairman shall hold office for seven (7) years, one
member for five (5) years, and the other member of three (3)
years. Appointment to any vacancy shall be only for the
capacity.
The chairman and the members of the Central Board shall be
Filipino citizens, at least forty(40) years old at the time of their
their appointment. The chairman of the Central Board shall have
the salary grade equivalent to the rank of Director III under the
Salary Standardization Law exclusive of allowances and other
emoluments. The members of the Central Board shall have the
salary grade equivalent to the rank of Director II under the Salary
Standardization Law exclusive of allowances and other
emoluments. The Central Board shall have appellate jurisdiction
over all assessment cases decided by the local board and
assessment appeals.
There shall be hearing officers to be appointed by the Central
Board pursuant to civil service law, rules and regulations, one
each of Luzon, Visayas, and Mindanao, who shall hold office in the
City of Manila, Cebu City, and Cagayan de Oro City, respectively,
and who shall serve for a term of six (6) years, without
reappointment until their successors shall have been appointed
and qualified.
The hearing officers shall have the same qualifications as those of
the Judges of the Municipal Trial Courts. The hearing officers
shall each have a salary grade equivalent to the rank of Director I
and other emoluments. The hearing officers shall try and receive
evidences on the appealed assessment cases as may be directed
by the Central Board.
The Central Board, in the performance of its powers and duties,
may establish and organize staffs, offices, or units, prescribe the
titles, functions and duties of their members, and adopt its own
rules and regulations.
Unless otherwise provided by law, the annual appropriations for
the Central Board shall be included in the annual budget of DOF.

(d) Appeal to the CTA
Republic Act 9282
March 30 2004

AN ACT EXPANDING THE JURISDICTION OF THE COURT OF TAX
APPEALS (CTA), ELEVATING ITS RANK TO THE LEVEL OF A
COLLEGIATE COURT WITH SPECIAL JURISDICTION AND
ENLARGING ITS MEMBERSHIP, AMENDING FOR THE PURPOSE
CERTAIN SECTIONS OR REPUBLIC ACT NO. 1125, AS AMENDED,
OTHERWISE KNOWN AS THE LAW CREATING THE COURT OF
TAX APPEALS, AND FOR OTHER PURPOSES

Section 1. Section 1 of Republic Act No. 1125, as amended is
hereby further amended to read as follows:

"SECTION 1. Court; Justices; Qualifications; Salary; Tenure. -
There is hereby created a Court of Tax Appeals (CTA) which shall
be of the same level as the Court of Appeals, possessing all the
inherent powers of a Court of Justice, and shall consist of a
Presiding Justice and five (5) Associate Justices. The incumbent
Presiding Judge and Associate Judges shall continue in office and
bear the new titles of Presiding Justice and Associate Justices. The
Presiding Justice and the most Senior Associate Justice shall serve

6
as chairmen of the two (2) Divisions. The additional three (3)
Justices and succeeding members of the Court shall be appointed
by the President upon nomination by the Judicial and Bar
Council. The Presiding Justice shall be so designated in his
appointment, and the Associate Justices shall have precedence
according to the date of their respective appointments, or when
the appointments of two (2) or more of them shall bear the same
date, according to the order in which their appointments were
issued by the President. They shall have the same qualifications,
rank, category, salary, emoluments and other privileges, be
subject to the same inhibitions and disqualifications, and enjoy
the same retirements and other benefits as those provided for
under existing laws for the Presiding Justice and Associate
Justices of the Court of Appeals.

"Whenever the salaries of the Presiding Justice and the Associate
Justices of the Court of Appeals are increased, such increases in
salaries shall be deemed correspondingly extended to and
enjoyed by the Presiding Justice and Associate Justices of the
CTA.

"The Presiding Justice and Associate Justices shall hold office
during good behavior, until they reach the age of seventy (70), or
become incapacitated to discharge the duties of their office,
unless sooner removed for the same causes and in the same
manner provided by law for members of the judiciary of
equivalent rank."

Section 2. Section 2 of the same Act is hereby amended to read as
follows:

"SEC. 2. Sitting En Banc or Division; Quorum; Proceedings. - The
CTA may sit en banc or in two (2) Divisions, each Division
consisting of three (3) Justices.

"Four (4) Justices shall constitute a quorum for sessions en banc
and two (2) Justices for sessions of a Division: Provided, That
when the required quorum cannot be constituted due to any
vacancy, disqualification, inhibition, disability, or any other
lawful cause, the Presiding Justice shall designate any Justice of
other Divisions of the Court to sit temporarily therein.

"The affirmative votes of four (4) members of the Court en banc
or two (2) members of a Division, as the case may be, shall be
necessary for the rendition of a decision or resolution."

follows:

"SEC. 3. Clerk of Court; Division Clerks of Court; Appointment;
Qualification; Compensation. - The CTA shall have a Clerk of
Court and three (3) Division Clerks of Court who shall be
appointed by the Supreme Court. No person shall be appointed
Clerk of Court or Division Clerk of Court unless he is duly
authorized to practice law in the Philippines. The Clerk of Court
and Division Clerks of Court shall exercise the same powers and
perform the same duties in regard to all matters within the
Court's jurisdiction, as are exercised and performed by the Clerk
of Court and Division Clerks of Court of the Court of Appeals, in so
far as the same may be applicable or analogous; and in the
exercise of those powers and the performance of those duties
they shall be under the direction of the Court. The Clerk of Court
and the Division Clerks of Court shall have the same rank,
privileges, salary, emoluments, retirement and other benefits as
those provided for the Clerk of Court and Division Clerks of Court
of the Court of Appeals, respectively.'

follows:

"SEC. 4. Other Subordinate Employees. - The Supreme Court shall
appoint all officials and employees of the CTA, in accordance with
the Civil Service Law. The Supreme Court shall fix their salaries
and prescribe their duties."

follows:

"SEC. 5. Disqualifications. - No Justice or other officer or
employee of the CTA shall intervene, directly or indirectly, in the
management or control of any private enterprise which in any
way may be affected by the functions of the Court. Justices of the
Court shall be disqualified from sitting in any case on the same
grounds provided under Rule one hundred thirty-seven of the
Rules of Court for the disqualification of judicial officers. No
person who has once served in the Court in a permanent
capacity, either as Presiding Justice or as Associate Justice
thereof, shall be qualified to practice as counsel before the Court
for a period of one (1) year from his retirement or resignation."

follows:

"SEC. 6. Place of Office. - The CTA shall have its principal office in
Metro Manila and shall hold hearings at such time and place as it
may, by order in writing, designate."

follows:

"Sec. 7. Jurisdiction. - The CTA shall exercise:

"a. Exclusive appellate jurisdiction to review by appeal, as herein
provided:

"1. Decisions of the Commissioner of Internal Revenue in cases
involving disputed assessments, refunds of internal revenue
taxes, fees or other charges, penalties in relation thereto, or other
matters arising under the National Internal Revenue or other
laws administered by the Bureau of Internal Revenue;

"2. Inaction by the Commissioner of Internal Revenue in cases
involving disputed assessments, refunds of internal revenue
taxes, fees or other charges, penalties in relations thereto, or
other matters arising under the National Internal Revenue Code
or other laws administered by the Bureau of Internal Revenue,
where the National Internal Revenue Code provides a specific
period of action, in which case the inaction shall be deemed a
denial;

"3. Decisions, orders or resolutions of the Regional Trial Courts in
local tax cases originally decided or resolved by them in the
exercise of their original or appellate jurisdiction;

"4. 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 in relation thereto, or other matters arising under
the Customs Law or other laws administered by the Bureau of
Customs;

7

"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;

"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;

"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 Republic Act No. 8800,
where either party may appeal the decision to impose or not to
impose said duties.

"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 o 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.

"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.

"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.

"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."

Section 8. Section 10 of the same Act is hereby amended to read
as follows:

"SEC. 10. Power to Administer Oaths; Issue Subpoena; Punish for
Contempt. - The Court shall have the power to administer oaths,
receive evidence, summon witnesses by subpoena duces tecum,
subject in all respects to the same restrictions and qualifications
as applied in judicial proceedings of a similar nature. The Court
shall, in accordance with Rule seventy-one of the Rules of Court,
have the power to punish for contempt for the same causes,
under the same procedure and with the same penalties provided
therein."

as follows:

"SEC. 11. Who May Appeal; Mode of Appeal; Effect of 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 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) herein.

"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 from the receipt of the decision or ruling or 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.

"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.

"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

8
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: Provided, however, That when in the opinion of
the Court the collection by the aforementioned government
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 to deposit the
amount claimed or 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."

as follows:

"SEC. 13. Decision, Maximum Period for Termination of Cases. -
Cases brought before the Court shall be decided in accordance
with Section 15, paragraph (1), Article VIII (Judicial Department)
of the 1987 Constitution. Decisions of the Court shall be in
writing, stating clearly and distinctly the facts and the law on
which they are based, and signed by the Justices concurring
therein. The Court shall provide for the publication of its decision
in the Official Gazette in such form and manner as may best be
adopted for public information and use.

"The Justices of the Court shall each certify on their applications
for leave, and upon salary vouchers presented by them for
payment, or upon the payrolls under which their salaries are
paid, that all proceedings, petitions and motions which have been
submitted to the Court for determination or decision for a period
required by the law or the Constitution, as the case may be, have
been determined or decided by the Court on or before the date of
making the certificate, and no leave shall be granted and no
salary shall be paid without such certificate."

Section 11. Section 18 of the same Act is hereby amended as
follows:

"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."

"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."

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.

Section 14. Retention of Personnel; Security of Tenure; Upgrading
of Positions and Salaries. - All existing permanent personnel of
the CTA shall not be adversely affected by this Act. They shall
continue in office and shall not be removed or separated from the
service except for cause as provided for by existing laws. Further,
the present positions and salaries of personnel shall be upgraded
to the level of their counterparts in the Court of Appeals.

Section 15. Transitory Provisions. - In consonance with the above
provision, the incumbent Presiding Judge and Associate Judges
shall comprise a Division pending the constitution of the entire
Court.

Section 16. Appropriations. - The amount necessary to carry out
the provisions of this Act shall be included in the General
Appropriations Act of the year following its enactment into law
and thereafter.

Section 17. Repealing Clause. - All laws, executive orders,
executive issuances or letter of instructions, or any part thereof,
inconsistent with or contrary to the provisions of this Act are
hereby deemed repealed, amended or modified accordingly.

(e) Appeal to the Supreme Court

Summary of Procedure for RPT Protest

1. Assessor submits assessment roll to Local Treasurer
(LT), Posting of notice of deadline for payment at a
conspicuous place at the LGU Hall or publish the same in a
newspaper of general circulation in the LGU once a week
for 2 consecutive weeks. LT collects the tax starting
January 1 of that calendar year.
2. Owner pays the tax. Written protest must be filed within
30 days from payment with the LT.
3. LT must decide within 60 days from receipt of protest
(Sec. 252). If LT does not decide within 60 days, or if LT
rejects protest, taxpayer may appeal within 60 days from
receipt of notice or lapse of 60 days (for inaction) to the
LBAA (Sec. 252). Refund or tax credit must be claimed with
the LT within 2 years from the date the taxpayer is entitled
to such refund (Sec. 253). If LT does not act on claim for
refund/tax credit within 60 days, OR does not grant the
refund/tax credit, taxpayer may appeal within 30 days
from receipt of notice or lapse of 60 days (for inaction) to
the LBAA (Sec. 226).
4. LBAA must decide within 120 days from receipt of
appeal.
5. If LBAA rejects protest/refund, taxpayer may appeal to
CBAA within 30 days from receipt of notice.
6. If CBAA rejects protest/refund, taxpayer may appeal to
CTA en banc within 30 days from receipt of decision (Rule
43, ROC).
7. Appeal the CTA en banc decision to SC within 15 days.


9
3. Claim for Refund for Illegal or Erroneous
Tax Payment
Sec. 253, LGC
SEC. 253. Repayment of Excessive Collections. - When an
assessment of basic real property tax, or any other tax levied
under this Title, is found to be illegal or erroneous and the tax is
accordingly reduced or adjusted, the taxpayer may file a written
claim for refund or credit for taxes and interests with the
provincial or city treasurer within two (2) years from the date
the taxpayer is entitled to such reduction or adjustment. The
provincial or city treasurer shall decide the claim for tax refund
or credit within sixty (60) days from receipt thereof. In case the
claim for tax refund or credit is denied, the taxpayer may avail of
the remedies as provided in Chapter 3, Title II, Book II of this
Code.
ARTICLE 344. Repayment of Excessive Collections. When an
assessment of basic real property tax, or any other tax levied in
this Rule, is found to be illegal or erroneous and the tax is
accordingly reduced or adjusted, the taxpayer may file a written
claim for refund or credit for taxes and interests with the
provincial or city treasurer within two (2) years from the date
the taxpayer is entitled to such reduction or adjustment.
The provincial or city treasurer shall decide the claim for tax
refund or credit within sixty (60) days from receipt thereof. In
case the claim for tax refund or credit is denied, the taxpayer may
avail of the remedies as provided in this Rule.

Claim for refund or Credit- when an assessment is found to
be illegal or erroneous and the tax is accordingly reduced
or adjusted (Sec. 253).

Procedure:
1. TP files a written claim for refund or credit with the
treasurer (within 2 years from the date the taxpayer is
entitled to such reduction or adjustment).
2. Provincial or city treasurer should decide the claim
within 60 days from receipt of the claim
3. In case of denial, appeal to the LBAA within 30 days as in
protest case

F. Special Levy on Real Property
In addition to the basic RPT, special levies may be
imposed by the same LGU on real property.

1. Special Education Fund
Sec. 235, LGC
SEC. 235. Additional Levy on Real Property for the Special
Education Fund. - A province or city, or a municipality within the
Metropolitan Manila Area, may levy and collect an annual tax of
one percent (1%) on the assessed value of real property which
shall be in addition to the basic real property tax. The proceeds
thereof shall exclusively accrue to the Special Education Fund
(SEF).
ARTICLE 326. Additional Levy on Real Property for the Special
Education Fund. A province or city, or a municipality within
MMA, may levy and collect an annual tax of one percent (1%) on
the assessed value of real property which shall be in addition to
the basic real property tax. The proceeds thereof shall exclusively
accrue to the special education fund.
All provinces and cities, and the municipalities within MMA shall
enact their respective tax ordinances imposing the additional tax
for the special education fund.
No public hearing shall be required before the enactment of a
local tax ordinance levying the additional one percent (1%)
special education fund tax.

SEF: 1% additional real estate tax to finance the SEF (Sec.
235)
RA 5447 created the SEF for specialized activities (like
purchase of educational materials, etc.) with its fund to be
derived from additional tax on real property and from
certain portion of the taxes on Virginia-type cigarettes and
duties on imported leaf tobacco.

2. Additional Ad Valorem Tax on Idle Lands
Sec. 236, LGC
SEC. 236. Additional Ad Valorem Tax on Idle Lands. - A province or
city, or a municipality within the Metropolitan Manila Area, may
levy an annual tax on idle lands at the rate not exceeding five
percent (5%) of the assessed value of the property which shall be
in addition to the basic real property tax.
ARTICLE 327. Additional Ad Valorem Tax on Idle Lands. A
province or city, or a municipality within MMA, may levy an
annual tax on idle lands at the rate not exceeding five percent
(5%) of the assessed value of the property which shall be in
addition to the basic real property tax.

Additional ad valorem on idle lands: not exceeding 5% of
the assessed value of the property

Rationale for imposing ad valorem taxes on idle lands: to
penalize property owners who do not use their property
productively, and to encourage utilization of land
resources in order to contribute to national development.

(a) Coverage of Idle Lands
Sec. 237, LGC
SEC. 237. Idle Lands, Coverage. - For purposes of real property
taxation, idle lands shall include the following:
(a) "Agricultural lands, more than one (1) hectare in area,
suitable for cultivation, dairying, inland fishery, and other
agricultural uses, one-half (1/2) of which remain uncultivated or
unimproved by the owner of the property or person having legal
interest therein." Agricultural lands planted to permanent or
perennial crops with at least fifty (50) trees to a hectare shall not
be considered idle lands. Lands actually used for grazing
purposes shall likewise not be considered idle lands.
(b) Lands, other than agricultural, located in a city or
municipality, more than one thousand (1,000) square meters in
area one-half (1/2) of which remain unutilized or unimproved by
the owner of the property or person having legal interest therein.
Regardless of land area, this Section shall likewise apply to
residential lots in subdivisions duly approved by proper
authorities, the ownership of which has been transferred to
individual owners, who shall be liable for the additional tax:
Provided, however, That individual lots of such subdivisions, the
ownership of which has not been transferred to the buyer shall
be considered as part of the subdivision, and shall be subject to
the additional tax payable by subdivision owner or operator.
ARTICLE 328. Idle Lands, Coverage. For purposes of real
property taxation, idle lands shall include the following:

10
(a) Agricultural lands, more than one (1) hectare in area, suitable
for cultivation, dairying, inland fishery, and other agricultural
uses, one-half () of which remain uncultivated or unimproved
by the owner of the property or person having legal interest
therein. Agricultural lands planted to permanent or perennial
crops with at least fifty (50) trees to a hectare shall not be
considered idle lands. Lands actually used for grazing purposes
shall likewise not be considered idle lands.
(b) Lands, other than agricultural, located in a city or
municipality, more than one thousand (1,000) square meters in
area one-half () of which remain unutilized or unimproved by
the owner of the property or person having legal interest therein.
Regardless of land area, this Article shall likewise apply to
residential lots in subdivisions duly approved by proper
authorities, the ownership of which has been transferred to
individual owners, who shall be liable for the additional tax
provided that individual lots of such subdivisions, the ownership
of which has not been transferred to the buyer shall be
considered as part of the subdivision, and shall be subject to the
additional tax payable by the subdivision owner or operator.

Lands considered idle:
1. Agricultural lands:
a. more than 1 hectare in area- if more than of which
remains uncultivated or unimproved by the owner of the
property or person having legal interest therein.
b. Not considered idle lands:
i. agricultural lands planted to permanent or
perennial crops with at least 50 trees to a hectare;
ii. lands actually used for grazing purposes shall
likewise not be considered idle lands
2. Non-agricultural lands: more than 1000 sq. m in are, if
more than of which remain unutilized or unimproved by
the owner of the property or person having legal interest
therein.

(b) Exempt Idle Lands
Sec. 238, LGC
SEC. 238. Idle Lands Exempt from Tax. - A province or city or a
municipality within the Metropolitan Manila Area may exempt
idle lands from the additional levy by reason of force majeure,
civil disturbance, natural calamity or any cause or circumstance
which physically or legally prevents the owner of the property or
person having legal interest therein from improving, utilizing or
cultivating the same.
ARTICLE 329. Idle Lands Exempt from Tax. A province or a
city or a municipality within MMA may exempt idle lands from
the additional levy by reason of force majeure, civil disturbance,
natural calamity, or any cause or circumstance which physically
or legally prevents the owner of the property or person having
legal interest therein from improving, utilizing, or cultivating the
same.

Idle lands may be exempted from the idle land tax by
reason of:
1. force majeure
2. civil disturbance
3. natural calamity
4. any cause which physically or legally prevents the
owner of the property or the person having legal interest
therein from improving, utilizing or cultivating the same.

(c) Listing of idle lands by the assessor
Sec. 239, LGC
SEC. 239. Listing of Idle Lands by the Assessor. - The provincial,
city or municipal assessor shall make and keep an updated
record of all idle lands located within his area of jurisdiction. For
purposes of collection, the provincial, city or municipal assessor
shall furnish a copy thereof to the provincial or city treasurer
who shall notify, on the basis of such record, the owner of the
property or person having legal interest therein of the imposition
of the additional tax.
ARTICLE 330. Listing of Idle Lands by the Local Assessor. The
provincial, city, or municipal assessor shall make and keep an
updated record of all idle lands located within his area of
jurisdiction. For purposes of collection, the provincial, city, or
municipal assessor shall furnish a copy thereof to the provincial
or city treasurer who shall notify, on the basis of such record, the
owner of the property or person having legal interest therein of
the imposition of the additional tax.

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TAXATION II (Carag) Reviewer Ann, Dana, David, Jenin and Sandy

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