Hilado v CIR

The Secretary of Finance is vested with authority to revoke, repeal or abrogate the
acts or previous rulings of his predecessors in office because the construction of a
statute by those administering it is not binding on their successors if the latter
becomes satisfied that a different construction should be given
Sison v Ancheta
The power to tax moreover, to borrow from Justice Malcolm, "is an attribute of
sovereignty. It is the strongest of all the powers of government." It is, of course, to
be admitted that for all its plenitude 'the power to tax is not unconfined. There are
restrictions. The Constitution sets forth such limits. Chief Justice Marshall said that
"the power to tax involves the power to destroy." The power to tax is not the power
to destroy while this Court sits. So it is in the Philippines.
Equality and uniformity of taxation means that all taxable articles or kinds of
property of the same class be taxed at the same rate. The taxing power has the
authority to make reasonable and natural classifications for purposes of taxation. To
satisfy this requirement it is enough that the statute or ordinance applies equally to
all persons, forms and corporations placed in similar situation.
CIR v Algue
It is said that 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. 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. This
symbiotic relationship is the rationale of taxation and should dispel the erroneous
notion that it is an arbitrary method of exaction by those in the seat of power. That
money due the government, either in the form of taxes or other dues, is its lifeblood
and should be collected without hindrance.
But even as we concede the inevitability and indispensability of taxation, it is a
requirement in all democratic regimes that it be exercised reasonably and in
accordance with the prescribed procedure. If it is not, then the taxpayer has a right
to complain and the courts will then come to his succor. For all the awesome power
of the tax collector, he may still be stopped in his tracks if the taxpayer can
demonstrate, as it has here, that the law has not been observed.
Tolentino v SEC of Finance
Equality and uniformity of taxation means that all taxable articles or kinds of
property of the same class be taxed at the same rate. The taxing power has the

authority to make reasonable and natural classifications for purposes of taxation. To

satisfy this requirement it is enough that the statute or ordinance applies equally to
all persons, forms and corporations placed in similar situation

Caltex v COA
It is settled that a taxpayer may not offset taxes due from the claims that he may
have against the government. Taxes cannot be the subject of compensation
because the government and taxpayer are not mutually creditors and debtors of
each other and a claim for taxes is not such a debt, demand, contract or judgment
as is allowed to be set-off.
Roxas v CTA
The power of taxation is sometimes called also the power to destroy. Therefore it
should be exercised with caution to minimize injury to the proprietary rights of a
taxpayer. It must be exercised fairly, equally and uniformly, lest the tax collector kill
the "hen that lays the golden egg". And, in order to maintain the general public's
trust and confidence in the Government this power must be used justly and not
treacherously. It does not conform with Our sense of justice in the instant case for
the Government to persuade the taxpayer to lend it a helping hand and later on to
penalize him for duly answering the urgent call.
Lutz v Araneta
Analysis of the Act, and particularly of section 6 (heretofore quoted in full), will show
that the tax is levied with a regulatory purpose, to provide means for the
rehabilitation and stabilization of the threatened sugar industry. In other words, the
act is primarily an exercise of the police power.
This Court can take judicial notice of the fact that sugar production is one of the
great industries of our nation, sugar occupying a leading position among its export
products; that it gives employment to thousands of laborers in fields and factories;
that it is a great source of the state's wealth, is one of the important sources of
foreign exchange needed by our government, and is thus pivotal in the plans of a
regime committed to a policy of currency stability. Its promotion, protection and
advancement, therefore redounds greatly to the general welfare.
Republic v Mambulao
"The general rule based on grounds of public policy is well-settled that no set-off
admissible against demands for taxes levied for general or local governmental
purposes. The reason on which the general rule is based, is that taxes are not in the
nature of contracts between the party and party but grow out of duty to, and are

the positive acts of the government to the making and enforcing of which, the
personal consent of individual taxpayers is not required.