Commisioner of Internal Revenue vs.

Manuel Pineda
GR No. L-22734. September 15, 1967
Bengzon, J.P., J.:
FACTS: On May 23, 1945, Antanasio Pineda died and was survived by his wife, Felicisima Bagtas, and 15 children, the eldest of
whom is Manuel Pineda. The estate was divided and awarded to the heirs, Manuel's share amounted to about 2,500 pesos. After
the estate proceeding were closed, the BIR investigated the income tax liability of the estate for the year 1945, 1946, 1947, and
1948 and it found that the corresponding income tax were not filed. Manuel Pineda, who recieved the assessment , contested the
same. Subsequently, he appealed to CTA, alleging that he was appealing "only that proportionate part or portion pertaining to him
as one of the heirs." CTA rendered judgment reversing the decision of the Commissioner appealed directly to SC.
ISSUE: Whether or not Manuel Pineda can be assessed for the whole amount of the tax liability.
HELD: Supreme Court ruled in affirmative.
RATIO: The Goverment has 2 ways of collecting the tax in question. One, by going after all the heirs and collecting from each
one of them the amount of tax proportionate to the inheritance received. This remedy was adopted in Government vs. Pamintuan,
et al. This action rests on the concept that heridetary property consist only of that part which remains after the settlement of all
lawful claims against the estate, for the settlement of which the entire estate is first liable. The reason why in case suit is filed
against all the heirs the tax due from the estate is levied proportionately against them is to achieve timely 2 results: first, payment
of the tax; and second, adjustment of the shares of each heir in the distributed estate as lessened by tax.
Another remedy, pursuant to the lien created by section 315 of the Tax Code upon all property and rights to property
belonging to the taxpayer for the unpaid income tax, is subjecting said property of the estate which is in the hand of transferee to
the payment of the tax due, the estate. The BIR should be given, in instances like the case at the bar, the necessary discretion to
avail itself of the most expeditious way to collect the tax as may be envisioned in the particular provision ofthe Tax Code above
qouted, because taxes are lifeblood of the government and their prompt and certain availability is an imperous need. This is the
very remedy which the government took in this particular case.