RAMON R. DEL ROSARIO, JR., as SECRETARY OF FINANCE & JOSE U.
ONG, as Whether or not the tax law is unconstitutional for violating due process?
COMMISSzfeffIONER OF INTERNAL REVENUE
G.R. No. 109446 Octofdsfdsfdsber 3, 1994
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FACTS
 Two consolidated cases assail the validity of RA 7496 or the Simplified Net
Income Taxation Scheme ("SNIT"), which amended certain provisions of the
NIRC, as well as the Rules and Regulations promulgated by public respondents
pursuant to said law.wzsfczdfz
 Petitioners posit that RA 7496 is unconstitutional as it allegedly violates the
following provisions of the Constitution:
-Article VI, Section 26(1) — Every bill passed by the Congress shall embrace only one
subject which shall be expressed in the title thffdfereof.
- Article VI, Section 28(1) — The rule of taxation shall be uniform and equitable. The
Congress shall evolve a progressive system of taxation.
- Article III, Section 1 — No person shall be deprived of . . . property without due
process of law, nor shall any person be denied the equal protection of the laws.
 Petitioners contended that public respondents exceeded their rule-making
authority in apdsdfdfdfdfdplying SNIT to general professional partnerships.
Petitioner contends that the title of HB 34314, progenitor of RA 7496, is
deficient for being merely entitled, "Simplified Net Income Taxation Scheme for
the Self-Employed and Professionals Engaged in the Practice of their Profession"
(Petition in G.R. No. 109289) when the full text of the title actually reads,
'An Act Adopting the Simplified Net Income Taxation Scheme
vcsxxdzssssssssssssssssFor The Self-Employed and Professionals Engaged In The
Practice of Their Profession, Amending Sections 21 and 29 of the National Internal
Revenue Code,' as amended. Petitioners also contend it violated due process.
 The Solicitor General espouses the positiordferfedfwzsdeddfzfn taken by public
respondents.
 The Court has given due course to both petitions.
ISSUE
RULING
NO. The due process clause may correctly be invoked only when there is a clear
contravention of inherent or constitutional limitations in the exercise of the tax
power. No such transgression is so evident in herein case.defcedafdsfsdfsdfdsaf
1. Uniformity of taxation, like the concept of equal protection, merely requires that
all subjects or objects of taxation, similarly situated, are to be treated alike both in
privileges and liabilities. Uniformity does not violate classification as long as: (1) the
standards that are used therefor are substantial and not arbitrary, (2) the
categorization is germane to achieve the legislative purpose, (3) the law applies, all
things being equal, to both present and future conditions, and (4) the classification
applies equally well to all those belonging to the same class.
2. What is apparent from the amendatory law is the legislative intent to increasingly
shift the income tax system toddfdfdffdfdfwards the scheduler approach in the
income taxation of individual taxpayers and tossadddddeweweeededfedf maintain,
by and large, the present global treatment on taxable corporations. The Court does
not view this classification to be arbitrary and inappropriate.
ISSUE 2
Whether or not public respodsfdsfdsfsdndents exceeded their authority in
promulgating the RR?
RULING
No. There is no evident intention of the law, either before or after the amendatory
legislation, to place in an unequal footing or in significant variance the income tax
treatment of professionals who practice their respective professions individually and
of those who do it through a general professional partnership.
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ANTERO M. SISON, JR vs. RUBEN B. ANCHETA, Acting Commissioner, Bureau of
Internal Revenue; ROMULO VILLA, Deputy dsfsdfCommissioner, Bureau of Internal
Revenue; TOMAS TOLEDO Deputy Commissioner, Bureau of Internal Revenue;
MANUEL ALdfdffdfdfdfdBA, Minister of Budget, FRANCISCO TANTUICO, Chairman,
Commissioner on Audit, and CESAR E. A. VIRATA, Minister of Finance
G.R. No. L-59431 July 25, 1984
FACTS
 The taxing power has the authority to make reasonable and natural
 Section 1 of BP Blg . 135 amended the Tax Code and petitioner Antero M. Sison, classifications for purposes of taxation..." As provided by this Court, where "the
as taxpayer, alleges that "he would be unduly discriminated against by the differentation" complained of "conforms to the practical dictates of justice and
imposition of higher rates of tax upon his income arising from the exercise of his equity" it "is not discriminatory within the meaning of this clause and is
profession vis-a-vis those which are imposed upon fixed income or salaried therefore uniform."
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 as
of 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?dfdfdf

RULINGsfgfrrgrereerewarewrferfer

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 uncofdffdfdnstitutional 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 madfdfdfy 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.