Gomez vs.

Palomar
Benefits-Protection Theory
The petitioner further argues that the tax in question is invalid, first, because it is not levied for a public purpose as
no special benefits accrue to mail users as taxpayers, and second, because it violates the rule of uniformity in
taxation.
The eradication of a dreaded disease is a public purpose, but if by public purpose the petitioner means benefit to a
taxpayer as a return for what he pays, then it is sufficient answer to say that the only benefit to which the taxpayer
is constitutionally entitled is that derived from his enjoyment of the privileges of living in an organized society,
established and safeguarded by the devotion of taxes to public purposes. Any other view would preclude the
levying of taxes except as they are used to compensate for the burden on those who pay them and would involve the
abandonment of the most fundamental principle of government — that it exists primarily to provide for the common
good.

PAL vs. Edu

Tax vs. Fees
Are motor vehicle registration fees taxes or regulatory taxes?
They are taxes. Tax are for revenue, whereas fees are exactions for purposes of regulation and inspection, and are for
that reason limited in amount to what is necessary to cover the cost of the services rendered in that connection. Fees
may be regarded as taxes even though they also serve as instruments of regulation because taxation may be made as
implementation of the State’s police power. If the purpose is primarily revenue, or if revenue is atleast one of the real
and substantial purposes, then the exaction is properly called a tax. It is the object of the charge, and not the name,
that determines whether a charge is a tax or a fee. The money collected under the Motor Vehicle Law is not intended
for the expenditures of the Motor Vehicle Law Office but accrues to the funds for the construction and maintenance
of public roads, streets and bridges. As the fees are not collected for regulatory purposes as an incident to the
enforcement of regulations governing the operation of motor vehicles on public highways, but to provide revenue
with which the Government is to construct and maintain public highways for everyone’s use, they are veritable taxes,
not merely fees. PAL is, thus, exempt from paying such fees, except for the period between June 27, 1968 to April 9,
1979, where its tax exception in the franchise was repealed.

CIR vs Pineda
Whether the Government can require Manuel Pineda to pay the full amount of the tax assessed
Yes. As a holder of property belonging to the estate, Pineda is liable for the tax up to the amount of the property in
his possession. The BIR is given the discretion to avail of the most expeditious way to collect the tax. This is, of
course, without prejudice to Pineda’s right of contribution for his co-heirs. Put simply, the Supreme Court held that
the rule on solidarity applies to taxes because it is not an ordinary contract. Two persons liable for payment of estate
tax:

1. Executor or administrator;
2. Heirs up to the extent of their inheritance.

Francia vs. CA
Tax vs. Debt(cannot be compensated)
Whether the expropriation payment may compensate for the real estate taxes due.
No. As a rule, set-off of taxes is not allowed. By legal compensation, obligations of persons, who in their own right are
reciprocally debtors and creditors of each other, are extinguished (Art. 1278, Civil Code). This is not applicable in
taxes. There can be no off-setting of taxes against the claims that the taxpayer may have against the government. A
person cannot refuse to pay a tax on the ground that the government owes him an amount equal to or greater than
the tax being collected. The collection of a tax cannot await the results of a lawsuit against the government. A claim
for taxes is not such a debt, demand, contract or judgment as is allowed to be set-off under the statutes of set-off,
which are construed uniformly, in the light of public policy, to exclude the remedy in an action or any indebtedness
of the state or municipality to one who is liable to the state or municipality for taxes. Neither are they a proper
subject of recoupment since they do not arise out of the contract or transaction sued on.

Domingo vs. Garlitos

Tax vs. Debt(exception)
Whether a tax and a debt may be compensated.
Compensation, therefore, takes place by operation of law, in accordance with Article 1279 and 1290 of the Civil Code,
and both debts are extinguished to their concurrent amounts. If the obligation to pay taxes and the taxpayer’s claim
against the government are both overdue, demandable, as well as fully liquidated, compensation takes place by
operation of law and both obligations are extinguished to their concurrent amounts.

Philex Mining vs. CIR

Tax vs. Debt(cannot be compensated)
Philex protested the demand for payment of the tax liabilities stating that it has pending claims for VAT input
credit/refund for the taxes it paid for the years 1989 to 1991 in the amount of P120 M plus interest. Therefore these
claims for tax credit/refund should be applied against the tax liabilities.
No. Philex's claim is an outright disregard of the basic principle in tax law that taxes are the lifeblood of the
government and so should be collected without unnecessary hindrance. Evidently, to countenance Philex's whimsical
reason would render ineffective our tax collection system. Too simplistic, it finds no support in law or in
jurisprudence.
To be sure, Philex cannot be allowed to refuse the payment of its tax liabilities on the ground that it has a pending
tax claim for refund or credit against the government which has not yet been granted.Taxes cannot be subject to
compensation for the simple reason that the government and the taxpayer are not creditors and debtors of each
other. There is a material distinction between a tax and debt. Debts are due to the Government in its corporate
capacity, while taxes are due to the Government in its sovereign capacity. xxx There can be no off-setting of taxes
against the claims that the taxpayer may have against the government. A person cannot refuse to pay a tax on the
ground that the government owes him an amount equal to or greater than the tax being collected. The collection of a
tax cannot await the results of a lawsuit against the government.

Vera vs. Fernandez

Taxes are obligations created by law. Taxes are never founded on contract or agreement, and are not dependent for
their validity upon the individual consent of the person taxed.
Under the familiar rule of statutory construction, the mention of one thing implies the exclusion of another thing not
mentioned.
Does the statute of non-claims of the Rules of Court bar the claim of the government for unpaid taxes?
No. The reason for the more liberal treatment of claims for taxes against a decedent's estate in the form of exception
from the application of the statute of non-claims, is not hard to find. Taxes are the lifeblood of the Government and
their prompt and certain availability are imperious need. (CIR vs. Pineda, 21 SCRA 105). Upon taxation depends the
Government ability to serve the people for whose benefit taxes are collected. To safeguard such interest, neglect or
omission of government officials entrusted with the collection of taxes should not be allowed to bring harm or
detriment to the people, in the same manner as private persons may be made to suffer individually on account of his
own negligence, the presumption being that they take good care of their personal affairs. This should not hold true to
government officials with respect to matters not of their own personal concern. This is the philosophy behind the
government's exception, as a general rule, from the operation of the principle of estoppel.