Sison vs Ancheta

GR No. L-59431, 25 July 1984

Facts: Section 1 of BP Blg 135 amended the Tax Code and petitioner Antero M. Sison, as
taxpayer, alleges that "he would be unduly discriminated against by the imposition of higher
rates of tax upon his income arising from the exercise of his profession vis-a-vis those which
are imposed upon fixed income or salaried individual taxpayers. He characterizes said
provision as arbitrary amounting to class legislation, oppressive and capricious in character.
It therefore violates both the equal protection and due process clauses of the Constitution as
well asof the rule requiring uniformity in taxation.

Issue: Whether or not the assailed provision violates the equal protection and due process
clauses of the Constitution while also violating the rule that taxes must be uniform and
equitable.

Held: The petition is without merit.

On due process - it is undoubted that it may be invoked where a taxing statute is so arbitrary
that it finds no support in the Constitution. An obvious example is where it can be shown to
amount to the confiscation of property from abuse of power. Petitioner alleges arbitrariness
but his mere allegation does not suffice and there must be a factual foundation of such
unconsitutional taint.
On equal protection - it suffices that the laws operate equally and uniformly on all persons
under similar circumstances, both in the privileges conferred and the liabilities imposed.
On the matter that the rule of taxation shall be uniform and equitable - this requirement is
met when the tax operates with the same force and effect in every place where the subject
may be found." Also, :the rule of uniformity does not call for perfect uniformity or perfect
equality, because this is hardly unattainable." When the problem of classification became of
issue, the Court said: "Equality and uniformity in taxation means that all taxable articles or
kinds of property of the same class shall be taxed the same rate. The taxing power has the
authority to make reasonable and natural classifications for purposes of taxation..." As
provided by this Court, where "the differentation" complained of "conforms to the practical
dictates of justice and equity" it "is not discriminatory within the meaning of this clause and is
therefore uniform."