G.R. No.

L-59431
ANTERO M. SISON v. RUBENANCHETA et a.

Facts:

Petitioner Antero Sison filed a taxpayers suit questioning the

constitutionality of Batas Pambansa Blg. 135 which amended Section 21 of
the NIRC. According to the petitioner he would be unduly discriminated by
the higher imposition of taxes on his income by the practice of his profession
as compared to those individuals who are taxed based on their fixed income.

Issue:

Whether or not subjecting the petitioner to a scheduler system of taxation

will unduly discriminate him thereby violating his right to equal protection
under the Constitution.

Held:

The Supreme Court dismissed the allegations of the petitioner. The

promotion of a scheduler system of taxation under BP Blg. 135 is not
violative of the equal protection clause provided for by the Constitution.

Taxpayers who are recipients of income are set apart as a class. Such is the
basis of the scheduler system of taxation, which is to be differentiated from
the global system of taxation or world taxation system, wherein the
collection of taxes is facilitated by a central international revenue service. As
there is practically no overhead expense, these taxpayers are not entitled to
make deductions for income tax purposes because they are in the same
situation more or less. On the other hand, in the case of professionals in the
practice of their calling and businessmen, there is no uniformity in the costs
or expenses necessary to produce their income. It would not be just then to
disregard the disparities by giving them all zero deductions and
indiscriminately impose on all alike the same tax rates on the basis of gross
income, while continuing the system of net income taxation as regards
professional business income.