30.

sec 205 B
SEC. 205. Remedies for the Collection of Delinquent Taxes. - The civil remedies
for the collection of internal revenue taxes, fees or charges, and any increment
thereto resulting from delinquency shall be:
(b) By civil or criminal action.
Either of these remedies or both simultaneously may be pursued in the discretion
of the authorities charged with the collection of such taxes: Provided, however
, That the remedies of distraint and levy shall not be availed of where the amou
nt of tax involve is not more than One hundred pesos (P100).
31. sec 23 D

(D) An alien individual, whether a resident or not of the Philippines, is taxabl

e only on income derived from sources within the Philippines;
Since hindi naman ininstall sa Phils yung program at sa China, hindi siya taxabl
e dito sa Pilpinas

32.

As stated above, the test of taxability under the exempting clause of Section 83
(b) is, whether income was realized through the redemption of stock dividends. T
he redemption converts into money the stock dividends which become a realized pr
ofit or gain and consequently, the stockholders separate property.[110] Profits
derived from the capital invested cannot escape income tax. As realized income,
the proceeds of the redeemed stock dividends can be reached by income taxation r
egardless of the existence of any business purpose for the redemption. Otherwise
, to rule that the said proceeds are exempt from income tax when the redemption
is supported by legitimate business reasons would defeat the very purpose of imp
osing tax on income. Such argument would open the door for income earners not to
pay tax so long as the person from whom the income was derived has legitimate b
usiness reasons. In other words, the payment of tax under the exempting clause o
f Section 83(b) would be made to depend not on the income of the taxpayer but on
the business purposes of a third party (the corporation herein) from whom the i
ncome was earned. This is absurd, illogical and impractical considering that the
Bureau of Internal Revenue (BIR) would be pestered with instances in determinin
g the legitimacy of business reasons that every income earner may interposed. It
is not administratively feasible and cannot therefore be allowed.
CIR vs CA - GR 108576

33.

Central to the second issue is Section 16 of the NIRC of 1977, as amended,[64] w

hich provides that the Commissioner of Internal Revenue has the power to make as
sessments and prescribe additional requirements for tax administration and enfor
cement. Among such powers are those provided in paragraph (b) thereof, which we
quote:
(b) Failure to submit required returns, statements, reports and other documents.
 When a report required by law as a basis for the assessment of any national int
ernal revenue tax shall not be forthcoming within the time fixed by law or regul
ation or when there is reason to believe that any such report is false, incomple
te or erroneous, the Commissioner shall assess the proper tax on the best eviden
ce obtainable.
In case a person fails to file a required return or other document at the time p
rescribed by law, or willfully or otherwise files a false or fraudulent return o
r other document, the Commissioner shall make or amend the return from his own k
nowledge and from such information as he can obtain through testimony or otherwi
se, which shall be prima facie correct and sufficient for all legal purposes
CIR vs Hantex Trading Co, GR 136975

34. sec 222 (C)

(c) Any internal revenue tax which has been assessed within the period of limita
tion as prescribed in paragraph (a) hereof may be collected by distraint or levy
or by a proceeding in court within five (5) years following the assessment of t
he tax.

35.
sec 22 B NIRC
(B) The term corporation shall include partnerships, no matter how created or orga
nized, joint-stock companies, joint account s (cuent as en part icipacion), asso
ciat ion, or insurance companies, but does not include general prof essional par
t nerships and a joint vent ure or consort ium f ormed f or t he purpose of unde
rt aking const ruct ion project s or engaging in pet roleum, coal, geot hermal a
nd ot her energy operat ions pursuant t o an operat ing consort ium agreement un
der a service cont ract wit h t he Government . General prof essional part nershi
ps are part nerships f ormed by persons f or t he sole purpose of exercising t he
ir common prof ession, no part of t he income of which is derived f rom engaging
in any t rade or business.
then segundahan mo neto
sec 26 NIRC
Section 26. Tax Liability of Members of General Professional Partnerships. A gen
eral professional part nership as such shall not be subject t o t he income t ax
imposed under t his Chapt er. Persons engaging in business as part ners in a ge
neral prof essional part nership shall be liable f or income t ax only in t heir
For
separat
purposes
e andofindividual
comput ingcapacit
t he dist
ies.1avvphil.n
ribut ive share
et of t he part ners, t he net
income of t he part nership shall be comput ed in t he same manner as a corpora
t ion.part ner shall report as gross income his dist ribut ive share, act ually o
Each
r const ruct ively received, in the net income of the partnership.
36. A.M. No. 05-11-07-CTA Rule 4 Sec 3 A
(2) Inaction by the Commissioner of Internal Revenue in cases involving disputed
assessments, refunds of internal revenue taxes, fees or other charges, penaltie
s in relation thereto, or other matters arising under the National Internal Reve
nue Code or other laws administered by the Bureau of Internal Revenue, where the
National Internal Revenue Code or other applicable law provides a specific peri
od for action: Provided, that in case of disputed assessments, the inaction of t
he Commissioner of Internal Revenue within the one hundred eighty day-period und
er Section 228 of the National Internal revenue Code shall be deemed a denial fo
r purposes of allowing the taxpayer to appeal his case to the Court and does not
necessarily constitute a formal decision of the Commissioner of Internal Revenu
e on the tax case; Provided, further, that should the taxpayer opt to await the
final decision of the Commissioner of Internal Revenue on the disputed assessmen
ts beyond the one hundred eighty day-period abovementioned, the taxpayer may app
eal such final decision to the Court under Section 3(a), Rule 8 of these Rules;
and Provided, still further, that in the case of claims for refund of taxes erro
neously or illegally collected, the taxpayer must file a petition for review wit
h the Court prior to the expiration of the two-year period under Section 229 of
the National Internal Revenue Code;
37. sec 90 B
(B) Time for filing. For the purpose of determining the estate tax provided for
in Section 84 of this Code, t he est at e t ax ret urn required under t he prece
ding Subsect ion (A) shall be f iled wit hin six (6) months from the decedents de
ath.
38. sec 32 3
(3) Gains derived from dealings in property;
39. sec 34 D 3
3) Net Operating Loss Carry-Over. T he net operat ing loss of t he business or e
tntaxable
erpriseyear
f orimmediat
any ely preceding t he current t axable year, which had not b
een previously of f set as deduct ion f rom gross income shall be carried over a
ts hree
a deduct
(3) consecut
ion f romivegross
t axable
incomeyears
f or immediat
t he nextely f ollowing t he year of such
Tloss:
hat any
Provided,
net losshowever,
incurred in a t axable year during which t he t axpayer was e
xempt f rom income t ax shall not be allowed as a deduct ion under t his Subsect
ion: Provided, f urt her, T hat a net operat ing loss carry-over shall be allow
ed only if there has been no substantial change in the ownership of the business
or ent erprise in t hat -
40. sec 6 F 2 NIRC
In case a t axpayer f iles an applicat ion t o compromise t he payment of his t
taxhat
liabilit
his f inancial
ies on hisposit
claimion demonst rat es a clear inabilit y t o pay t he t
ax assessed, his applicat ion shall not be considered unless and unt il he waive
s in writ ing his privilege under Republic act NO. 1405 or under ot her general
or special laws, and such waiver shall const it ut e t he aut horit y of t he Co
mmissioner t o inquire int o t he bank deposit s of t he t axpayer.
41. PRA vs City of Paranaque GR 191109
Indeed, the Republic grants the beneficial use of its real property to an
agency or instrumentality of the national government. This happens when
the title of the real property is transferred to an agency or instrumentality
even as the Republic remains the owner of the real property. Such
arrangement does not result in the loss of the tax exemption, unless the
beneficial use thereof has been granted, for consideration or otherwise, to a
taxable person."
Local Government Code, Section 234(a).
42. sec 35 b
(B) Addit ional Exempt ion f or Dependent s. T here shall be allowed an addit io
nal exempt ion of Eight t housand pesos (P8,000) f or each dependent not exceedi
Tnghef addit
our (4).ional exempt ion f or dependent shall be claimed by only one of t he
spouses
In t he case
in t of
he legally
case of separat
married ed
individuals.
spouses, addit ional exempt ions may be claim
ed only by t he spouse who has cust ody of t he child or children: Provided, T h
tathat
t hemayt be
ot claimed
al amountbyofbotaddit
h shall
ionalnotexempt
exceedions
t he maximum addit ional exempt i
ons purposes
For herein allowed.
of t his Subsect ion, a dependent means a legit imat e, illegit imat
e or legally adopt ed child chief ly dependent upon and living wit h t he t axp
ayer if such dependent is not more t han t went y- one (21) years of age, unmarr
ied and not gainfully employed or if such dependent, regardless of age, is incap
able of self-support because of mental or physical defect.
43. sec 99 c nirc
(C) Any cont ribut ion in cash or in kind t o any candidat e, polit ical part y
or coalit ion of part ies f or campaign purposes shall be governed by t he Elect
ion Code, as amended.
44. sec 208 nirc
Bank account s shall be garnished by serving a warrant of garnishment upon t he
t axpayer and upon t he president , manager, t reasurer or ot her responsible of
f icer of t he bank. Upon receipt of t he warrant of garnishment , t he bank sh
all t un over t o t he Commissioner so much of t he bank account s as may be suf
ficient to satisfy the claim of the Government.
45. In fact, fiscal adequacy dictated the need for a raise in revenue.
The principle of fiscal adequacy as a characteristic of a sound tax system was o
riginally stated by Adam Smith in his Canons of Taxation (1776), as:
IV. Every tax ought to be so contrived as both to take out and to keep out of th
e pockets of the people as little as possible over and above what it brings into
the public treasury of the state.
The Wealth of Nations, Book V, Chapter II.
46. Taxes may be inherently punitive, but when the fine line
between damage and destruction is crossed, the courts must step forth
and cut the hangman s noose. Justice Holmes once confidently asserted
that the power to tax is not the power to destroy while this Court sits
and we should very well live up to this expectation not only of the
revered Holmes, but of the Filipino people who rely on this Court as the
guardian of their rights. At stake is the right to exist and subsist despite
taxes, which is encompassed in the due process clause.
Abakada Guro Party List v. Ermita, 506 Phil. 1, 251 (2005)
47. sec 204 (a) (1)
Section 204. Authority of the Commissioner to Compromise, Abate and Refund or Cr
editACompromise
(A)
(1) Taxes.
reasonable
Tthedoubt
heCommissioner
payment
as t ooftany
mayvalidit
he int
- ernaly of
revenue
t he claim
t ax, against
when: t he t axpaye
r exist s; or
48. sec 23 (f)
(F) A f oreign corporat ion, whet her engaged or not in t rade or business in t
he Philippines, is t axable only on income derived f rom sources wit hin t he Ph
ilippines.
49. Sec 112 D
(D) Period within which Refund or Tax Credit of Input Taxes shall be Made. In pr
oper cases, t he Commissioner shall grant a ref und or issue t he t ax credit ce
rt if icat e f or credit able input t axes wit hin one hundred t went y (120) da
ys f rom t he dat e of submission of compet e document s in support of t he appl
icatcase
In ionoff full
iled or
in partial
accordance
denial
wit of
h Subsect
the claim
ionsfor(A)taxandrefund
(B) hereof
or tax.credit, or
the failure on the part of the Commissioner t o act on t he applicat ion wit hin
t he period prescribed above, t he t axpayer af f ect ed may, within thirty (30
) days from the receipt of the decision denying the claim or after the expiratio
n of theonehundredtwentyday-period,appealthedecisionortheunactedclaimwiththeCour
t of Tax Appeals.-
50. sec 18 LGC
SECTION 18. Power to Generate and Apply Resources. - Local government units shal
l have the power and authority to establish an organization that shall be respon
sible for the efficient and effective implementation of their development plans,
program objectives and priorities; to create their own sources of revenue and t
o levy taxes, fees, and charges which shall accrue exclusively for their use and
disposition and which shall be retained by them; to have a just share in nation
al taxes which shall be automatically and directly released to them without need
of any further action; to have an equitable share in the proceeds from the util
ization and development of the national wealth and resources within their respec
tive territorial jurisdictions including sharing the same with the inhabitants b
y way of direct benefits; to acquire, develop, lease, encumber, alienate, or oth
erwise dispose of real or personal property held by them in their proprietary ca
pacity and to apply their resources and assets for productive, developmental, or
welfare purposes, in the exercise or furtherance of their governmental or propr
ietary powers and functions and thereby ensure their development into self-relia
nt communities and active participants in the attainment of national goals.
51. sec 99 (b)
(B) Tax Payable by Donor if Donee is a Stranger. When t he donee or benef iciary
is st ranger, t he t ax payable by the donor shall be thirty percent (30%) of t
he net
(1) Brother,
gifts.sister
For the(whether
purposebyofwhole
this or
tax,half-blood),
a st ranger,
spouse,
is aancestor
person who
andislinea
not a:
l descendant; or (2) Relat ive by consanguinit y in t he collat eral line wit hi
n t he f ourt h degree of relat ionship.
52. sec 32 7 d b
(d) Prizes and Awards in sport s Compet it ion. All prizes and awards grant ed t
o at hlet es in local and int ernat ional sport s compet it ions and t ournamen
t s whet her held in t he Philippines or abroad and sanct ioned by t heir nat io
nal sport s associat ions.
53. Sec 3514 TCC -
(medyo winding ako sa part na to, explain mo n lng authority ng BOC to ask for p
ayment of customs duties
54. Sec 228 (e)
If t he prot est is denied in whole or in part , or is not act ed upon wit hin o
ne hundred eight y (180) days f rom submission of document s, t he t axpayer adv
ersely af f ect ed by t he decision or inact ion may appeal to the Court of T ax
Appeals within thirty (30) days from receipt of the said decision, or from the
lapse of one hundred eighty (180)-day period; otherwise, the decision shall beco
me final, executory and demandable.
(A) TSection
55. here shall
98. Imposition
be levied,ofassessed,
Tax. - NIRC
collect ed and paid upon t he t ransf er b
y any person, resident or nonresident , of t he propert y by gif t , a t ax, com
put ed as provided in Sect ion 99.
56. Sec 139 (B) LGC
(b) Every person legally authorized to practice his profession shall pay the pro
fessional tax to the province where he practices his profession or where he main
tains his principal office in case he practices his profession in several places
: Provided, however, That such person who has paid the corresponding professiona
l tax shall be entitled to practice his profession in any part of the Philippine
s without being subjected to any other national or local tax, license, or fee fo
r the practice of such profession.cralaw
57. Sec 248 (B) NIRC
(B) In case of willf ul neglect t o f ile t he ret urn wit hin t he period presc
ribed by t his Code or by rules and regulat ions, or in case a f alse or f raudu
lent ret urn is willf ully made, t he penalt y t o be imposed shall be fifty per
cent (50%) of the tax or of the deficiency tax, in case, any payment has been ma
de on the basis of such ret urn bef ore t he discovery of t he f alsit y or f ra
ud: Provided, T hat a subst ant ial underdeclarat ion of t axable sales, receipt
s or income, or a subst ant ial overst at ement of deduct ions, as det ermined
by t he Commissioner pursuant t o t he rules and regulat ions t o be promulgat e
d by t he Secret ary of Finance, shall const it ut e prima f acie evidence of a
f urt
alseher,
or fTraudulent
hat f ailure
ret turn:
o report
Provided,
sales, receipt s or income in an amount exc
eeding t hirt y percent (30%) of t hat declared per ret urn, and a claim of dedu
ct ions in an amount exceeding (30%) of act ual deduct ions, shall render t he t
axpayer liable f or subst ant ial underdeclarat ion of sales, receipt s or inco
me or f or overst at ement of deduct ions, as ment ioned herein.
58. Sec 32 (B) (1) NIRC
(B) Exclusions from Gross Income. T he f ollowing it ems shall not be included i
n gross income and shall
be exempt from taxation under this
(1)LifeInsurance.Theproceedsof lifeinsurancepoliciespaidtotheheirsorbeneficiaries
title:
uponthe deat h of t he insured, whet her in a single sum or ot herwise, but if s
uch amount s are held by t he insurer under an agreement t o pay int erest t her
eon, t he int erest payment s shall be included in gross income.
59. Sec 34 (D) (3) NIRC
Revenue Regulations No. 12-99, Implementing the Provisions of the National Inter
nal Revenue Code of 1997 Governing the Rules on Assessment of National Internal
Revenue Taxes, Civil Penalties and Interest and the Extra-judicial Settlement of
a Taxpayer s Criminal Violation of the Code Through Payment of a Suggested Comp
romise Penalty, 6 September 1999.
Sec. 3.1.5 Disputed Assessment. The taxpayer or his duly authorized representati
ve may protest administratively against the aforesaid formal letter of demand an
d assessment notice within thirty (30) days from date of receipt thereof. If the
re are several issues involved in the formal letter of demand and assessment not
ice but the taxpayer only disputes or protests against the validity of some of t
he issues raised, the taxpayer shall be required to pay the deficiency tax or ta
xes attributable to the undisputed issues, in which case, a collection letter sh
all be issued to the taxpayer calling for payment of the said deficiency tax, in
clusive of the applicable surcharge and/or interest. No action shall be taken on
the taxpayer s disputed issues until the taxpayer has paid the deficiency tax o
r taxes attributable to the said undisputed issues. The prescriptive period for
assessment or collection of the tax or taxes attributable to the disputed issues
shall be suspended.
60. CIR vs First Express Pawnshop Company GR 172045-46
[49] Revenue Regulations No. 12-99, Implementing the Provisions of the National
Internal Revenue Code of 1997 Governing the Rules on Assessment of National Inte
rnal Revenue Taxes, Civil Penalties and Interest and the Extra-judicial Settleme
nt of a Taxpayer s Criminal Violation of the Code Through Payment of a Suggested
Compromise Penalty, 6 September 1999.
Sec. 3.1.5 Disputed Assessment. The taxpayer or his duly authorized representati
ve may protest administratively against the aforesaid formal letter of demand an
d assessment notice within thirty (30) days from date of receipt thereof. If the
re are several issues involved in the formal letter of demand and assessment not
ice but the taxpayer only disputes or protests against the validity of some of t
he issues raised, the taxpayer shall be required to pay the deficiency tax or ta
xes attributable to the undisputed issues, in which case, a collection letter sh
all be issued to the taxpayer calling for payment of the said deficiency tax, in
clusive of the applicable surcharge and/or interest. No action shall be taken on
the taxpayer s disputed issues until the taxpayer has paid the deficiency tax o
r taxes attributable to the said undisputed issues. The prescriptive period for
assessment or collection of the tax or taxes attributable to the disputed issues
shall be suspended.
61. Sec 105 (t) Tariff and Customs Code (TCC)
t. Philippine articles previously exported from the Philippines and returned wit
hout having been advanced in value or improved in condition by any process of ma
nufacture or other means, and upon which no drawback or bounty has been allowed,
including instruments and implements, tools of trade, machinery and equipment,
used abroad by Filipino citizens in the pursuit of their business, occupation or
profession; and foreign articles previously imported when returned after having
been exported and loaned for use temporarily abroad solely for exhibition, test
ing and experimentation, for scientific or educational purposes; and foreign con
tainers previously imported which have been used in packing exported Philippine
articles and returned empty if imported by or for the account of the person or i
nstitution who exported them from the Philippines and not for sale, barter or hi
re subject to identification: Provided, That any Philippine article falling unde
r this subsection upon which drawback or bounty has been allowed shall, upon re-
importation thereof, be subject to a duty under this subsection equal to the amo
unt of such drawback or bounty.
62. RA 6938 - Sec 62 (3)
ARTICLE 62. Tax and Other Exemptions. Cooperatives transacting business with bot
h members and nonmembers shall not be subject to tax on their transactions to me
mbers.
-or pwede rin ito-
PFDA vs CBAA GR 178030
Sections 193, 232, and 234 of the Local Government Code which read:

Section 193. Withdrawal of Tax Exemption Privileges. Unless otherwise provided i

n this Code, tax exemptions or incentives granted to, or presently enjoyed by al
l persons, whether natural or juridical, including government-owned or -controll
ed corporations, except local water districts, cooperatives duly registered unde
r R.A. No. 6938, non-stock and non-profit hospitals and educational institutions
, are hereby withdrawn upon the effectivity of this Code.

Section 232. Power to Levy Real Property Tax. A province or city or a municipali
ty within the Metropolitan Manila Area may levy an annual ad valorem tax on real
property such as land, building, machinery, and other improvement not hereinaft
er specifically exempted.

Section 234. Exemptions from Real Property Tax. The following are exempted from
payment of the real property tax:
(a) Real property owned by the Republic of the Philippines or any of its politic
al subdivision except when the beneficial use thereof has been granted, for cons
ideration or otherwise, to a taxable person;
(b) Charitable institutions, churches, parsonages or convents appurtenant theret
o, mosques, nonprofit or religious cemeteries and all lands, buildings and impro
vements actually, directly, and exclusively used for religious, charitable or ed
ucational purposes;
(c) All machineries and equipment that are actually, directly and exclusively us
ed by local water districts and government-owned or -controlled corporations eng
aged in the supply and distribution of water and/or generation and transmission
of electric power;
(d) All real property owned by duly registered cooperatives as provided for unde
r R.A. No. 6938; and
(e) Machinery and equipment used for pollution control and environmental protect
ion.

Except as provided herein, any exemption from payment of real property tax previ
ously granted to, or presently enjoyed by, all persons, whether natural or jurid
ical, including all government-owned or -controlled corporations are hereby with
drawn upon the effectivity of this Code.

63. "SEC. 1802. Abandonment of Imported Articles.

An abandoned article shall ipso facto be deemed the property of the Government a
nd shall be disposed of in accordance with the provisions of this Code.
64. Sec 248 (B)
65. Sec 23 (D)
(D) An alien individual, whet her a resident or not of t he Philippines, is t ax
able only on income derived f rom sources wit hin t he Philippines;
66. Art XIV Sec 4 (3)
(3) All revenues and assets of non-stock, non-profit educational institutions us
ed actually, directly, and exclusively for educational purposes shall be exempt
from taxes and duties. Upon the dissolution or cessation of the corporate existe
nce of such institutions, their assets shall be disposed of in the manner provid
ed by law.
67. Sec 34 (C) (5)
68. REVENUE REGULATIONS NO. 30-2002 Sec 3 (1) (a)
SEC. 3. BASIS FOR ACCEPTANCE OF COMPROMISE
SETTLEMENT. - The Commissioner may compromise the payment of any internal
revenue tax on the following grounds:
1. Doubtful validity of the assessment. - The offer to compromise a
delinquent account or disputed assessment under these Regulations on
the ground of reasonable doubt as to the validity of the assessment may
be accepted when it is shown that:
(a) The delinquent account or disputed assessment is one resulting
from a jeopardy assessment (For this purpose, jeopardy
assessment shall refer to a tax assessment which was assessed
without the benefit of complete or partial audit by an
authorized revenue officer, who has reason to believe that the
assessment and collection of a deficiency tax will be
jeopardized by delay because of the taxpayers failure to
comply with the audit and investigation requirements to present
his books of accounts and/or pertinent records, or to
substantiate all or any of the deductions, exemptions, or credits
claimed in his return); or
69. Sec 29 (2), Philippines Constitution
70. Sec. 304. Discrimination by Foreign Countries.
a. The President, when he finds that the public interest will be serves thereby,
shall by proclamation specify and declare new or additional duties in an amount
not exceeding one hundred (100) per cent ad valorem upon articles wholly or in
part the growth or product of, or imported in a vessel of, any foreign country w
henever he shall find as a fact that such country
1. Imposes, directly or indirectly, upon the disposition or transportation in tr
ansit through or re-exportation from such country of any article wholly or in pa
rt the growth or product of the Philippines, any unreasonable charge, exaction,
regulation or limitation which is not equally enforced upon the like articles of
every foreign country; or
2. Discriminates in fact against the commerce of the Philippines, directly or in
directly, by law or administrative regulation or practice, by or in respect to a
ny customs, tonnage, or port duty, fee, charge, exaction, classification, regula
tion, condition, restriction or prohibition, in such manner as to place the comm
erce of the Philippines at a disadvantage compared with the commerce of any fore
ign country.
b. If at any time the President shall find it to be a fact that any foreign coun
try has not only discriminated against the commerce of the Philippines, as afore
said, but has, after the issuance of a proclamation as authorized in subsection
"a" of this section, maintained or increased its said discrimination against the
commerce of the Philippines, the President is hereby authorized, if he deems it
consistent with the interests of the Philippines, to issue a further proclamati
on directing that such product of said country or such article imported in its v
essels as he shall deem consistent with the public interests, shall be excluded
from importation into the Philippines.
c. Any proclamation issued by the President under this section shall, if he deem
s it consistent with the interest of the Philippines, extend to the whole of any
foreign country or may be confined to any subdivision or subdivisions thereof;
and the President shall, whenever he deems the public interests require, suspend
, revoke, supplement or amend any such proclamation.
d. All articles imported contrary to the provisions of this section shall be for
feited to the Government of the Philippines and shall be liable to be seized, pr
osecuted and condemned in like manner and under the same regulations, restrictio
ns and provisions as may from time to time be established for the recovery, coll
ection, distribution and remission or forfeiture to the government by the tariff
and customs laws. Whenever the provision of this section shall be applicable to
importations into the Philippines of articles wholly or in part the growth or p
roduct of any foreign country, they shall be applicable thereto, whether such ar
ticles are imported directly or indirectly.
e. It shall be the duty of the Commission to ascertain and at all times to be in
formed whether any of the discrimination against the commerce of the Philippines
enumerated in subsections "a" and "b" of this section are practiced by any coun
try; and if and when such discriminatory acts are disclosed, it shall be the dut
y of the Commission to bring the matter to the attention of the President, toget
her with recommendations.
f. The Secretary of finance shall make such rules and regulations as are necessa
ry for the execution of such proclamation as the President may issue in accordan
ce with the provisions of this section.
71. Sec 228
72. Sec 222 (e)
73. DOCTRINE OF SYMBIOTIC RELATIONSHIP
This doctrine is enunciated in CIR v. Algue, Inc. [158 SCRA 9], which states tha
t Taxes are what we pay for civilized society. Without taxes, the government woul
d be paralyzed for lack of the motive power to activate and operate it. Hence, d
espite the natural reluctance to surrender part of ones hard-earned income to the
taxing authorities, every person who is able must contribute his share in the b
urden of running the government. The government for its part, is expected to res
pond in the form of tangible and intangible benefits intended to improve the liv
es of the people and enhance their material and moral values.
74. Sec 115 (b)
75. Sec 30 (E)