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Philippine Supreme Court Jurisprudence > Year 2016 > June 2016 Decisions > G.R. No. 194065, June 20, 2016 -
PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.:
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G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
FIRST DIVISION
DECISION
SERENO, C.J.:
THE FACTS
Pursuant to Revenue Regulations (RR) No. 7-92, the Bureau of Internal Revenue (BIR) issued Certificate
No. 08-0434 on 31 July 2001 authorizing petitioner to operate and use the On-line Electronic
Documentary Stamp Metering Machine (DS metering machine) with Serial No. SN363 1711.
Petitioner purchased documentary stamps from the BIR and loaded them to its DS metering machine.
During the period 23 March 2004 to 23 December 2004, petitioner executed several repurchase
agreements with the Bangko Sentral ng Pilipinas (BSP). The documentary stamps were imprinted on the
Confirmation Letters corresponding to those repurchase agreements through petitioner's DS metering
DebtKollect Company, Inc. machine.
Petitioner claimed that the repurchase agreements were not subject to the documentary stamp tax
(DST). Thus, on 12 May 2006, it filed with the BIR an administrative claim for the issuance of tax credit
certificates for the alleged erroneous payment of the DST in the total amount of P11,063,866.67.
Alleging the inaction of the BIR on the administrative claim of petitioner, the latter filed a Petition for
Review with the CTA on 18 May 2006. Petitioner reiterated its claim for the refund or issuance of its tax
credit certificate for the amount of P11,063,866.67 representing the erroneously paid DST for several
repurchase agreements it had executed with the BSP.
The CTA Division found that the evidence adduced by petitioner showed that the latter had duly executed
various repurchase agreements with the BSP from 23 March 2004 to 23 December 2004. It further held
that the repurchase agreements were exempt from the imposition of the DST pursuant to Section 9 of
Republic Act (R.A.) No. 9243,5 which provides:ChanRoblesVirtualawlibrary
SECTION 9. Section 199 of the National Internal Revenue Code of 1997, as amended is
hereby further amended to read as follows:
SEC. 199. Documents and Papers Not Subject to Stamp Tax. - The
ChanRobles Intellectual Property chanRoblesvirtualLawlibrary
xxxx
chanRoblesvirtualLawlibrary
(h) Derivatives: Provided, That for purposes of this exemption, repurchase agreements
and reverse repurchase agreements shall be treated similarly as derivatives.
xxxx
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
(l) All contracts, deeds, documents and transactions related to the conduct of business of
the Banko Sentral ng Pilipinas.
Although the DST on the repurchase agreements were paid, the CTA Division found that petitioner had
substantiated only P10,633,881.20. Out of that amount, P3,072,521.60 was barred by prescription, and
only the claim for the remaining P7,561,359.60 fell within the two-year prescriptive period. The CTA
Division reckoned the counting of the two-year period from the date of the Confirmation Letters of the
repurchase agreements. Considering that petitioner filed its administrative claim on 12 May 2006 and the
judicial claim on 18 May 2006, the DST paid on the repurchase agreements earlier than 18 May 2004
was disallowed due to prescription.
The CTA en banc ruled that insofar as the taxpayers using the DS metering machine were concerned, the
DST was deemed paid upon the purchase of documentary stamps for loading and reloading on the DS
metering machine, through the filing of the DST Declaration under BIR Form No. 2000. Thus, the two-
year prescriptive period for taxpayers using DS metering machine started to run from the date of filing of
the DST Declaration under BIR Form No. 2000, and not from the date appearing on the documentary
stamp imprinted through the DS metering machine. Consequently, the refundable amount was further
reduced to P5,238,495.40 representing the erroneously paid DST that had not yet been barred by
prescription.
ISSUE
The arguments raised by petitioner boil down to the sole issue of whether the date of imprinting the
documentary stamps on the document or the date of purchase of documentary stamps for loading and
reloading on the DS metering machine should be deemed as payment of the DST contemplated under
Section 200 (D) of the NIRC for the purpose of counting the two-year prescriptive period for filing a claim
for a refund or tax credit.
G.R. No. 175085, June 01, 2016 - TAN SIOK1 KUAN In relation thereto, the BIR has issued the following regulations:ChanRoblesVirtualawlibrary
AND PUTE CHING, Petitioners, v. FELICISIMO "BOY"
HO, RODOLFO C. RETURTA, VICENTE M. SALAS, AND REVENUE REGULATIONS NO. 05-979
LOLITA MALONZO, Respondents.
SUBJECT: Revised Regulations Prescribing the New Procedure on the Purchase and
G.R. No. 211672, June 14, 2016 - PEOPLE OF THE Affixture of Documentary Stamp on Taxable Documents/Transactions
PHILIPPINES, Plaintiff-Appellee, v. JOHN HAPPY
DOMINGO Y CARAG, Accused-Appellant.
xxxx
G.R. No. 204056, June 01, 2016 - GIL MACALINO,
JR., TERESITA MACALINO, ELPIDIO MACALINO, PILAR
SECTION 4. New Procedure on Purchase of a Documentary Stamp for Use in BIR
MACALINO, GILBERTO MACALINO, HERMILINA Registered Metering Machine. — Purchase of Documentary Stamps for future applications
MACALINO, EMMANUEL MACALINO, EDELINA not covered by Sections 2 and 3 of these Regulations shall be allowed only to persons
MACALINO, EDUARDO MACALINO, LEONARDO authorized to use BIR Registered Metering Machine under Revenue Regulations No. 7-92,
MACALINO, EDLLANE** MACALINO, APOLLO dated September 7, 1992.
MACALINO, MA. FE MACALINO, AND GILDA
MACALINO, Petitioners, v. ARTEMIO PIS-AN, SECTION 5. Documentary Stamp Tax Declaration. — The following persons are required to
Respondent. accomplish and file a documentary stamp tax declaration under BIR Form 2000;
G.R. No. 211290, June 01, 2016 - OMBUDSMAN- xxxx
MINDANAO, Petitioner, v. LILING LANTO IBRAHIM,
PROJECT MANAGER, NATIONAL IRRIGATION
ADMINISTRATION, NIA-PIO, LANAO DEL NORTE, 5.3 Any person duly authorized to use DST Metering Machine shall file a DST
Respondent.
Declaration under BIR Form No. 2000 each time documentary stamps
are purchased for loading or reloading on the said machine. This
G.R. No. 205061, June 08, 2016 - EMERTIA G.
MALIXI, Petitioner, v. MEXICALI PHILIPPINES
declaration shall be filed with any duly Authorized Agent Bank, Revenue
AND/OR FRANCESCA MABANTA, Respondents. Recollection Officer, or duly authorized City or Municipal Treasurer in the
Philippines. The amount of documentary stamps to be reloaded on the Metering
G.R. No. 208137, June 08, 2016 - MARIA CECILIA Machine should be equal to the amount of documentary stamps consumed from
OEBANDA, EXECUTIVE DIRECTOR AND/OR THE previous purchase. The details of usage or consumption of documentary stamps
OCCUPANTS AND EMPLOYEES OF VISAYAN FORUM should be indicated on the declaration.
FOUNDATION, INC., Petitioners, v. PEOPLE OF THE
PHILIPPINES, Respondent.
On the basis of these provisions, the CTA en banc ruled in this case that payment of the DST was done
G.R. No. 203750, June 06, 2016 - JORGE B. when the documentary stamps were loaded/reloaded on the DS metering machine and the
NAVARRA, Petitioner, v. PEOPLE OF THE PHILIPPINES, corresponding DST Declaration was filed. Thus, the two-year prescriptive period for the claim for a
HONGKONG AND SHANGHAI BANKING CORPORATION, refund of petitioner's erroneously paid DST was reckoned from the date the DS metering machine was
Respondents. reloaded.
G.R. No. 209146, June 08, 2016 - PROVINCE OF The CTA en banc, in ruling on the particular issue of prescription, said that RR No. 05-97 should govern
ANTIQUE AND MUNICIPALITY OF CALUYA, Petitioners,
the payment of the DST considering that petitioner is a DS metering machine user. The DST is deemed
v. HON. RECTO A. CALABOCAL, JUDGE-DESIGNATE,
paid upon the purchase of documentary stamps for loading/reloading on the DS metering machine
REGIONAL TRIAL COURT, BRANCH 43, ROXAS,
ORIENTAL MINDORO, PROVINCE OF ORIENTAL
through the filing of the DST Declaration (BIR Form No. 2000) as required by the said regulation.
MINDORO, AND MUNICIPALITY OF BULALACAO,
Respondents. We do not agree.
G.R. No. 200180, June 06, 2016 - BENJAMIN H. The DS metering machine was developed and used for businesses with material DST transactions like
CABAÑEZ, Petitioner, v. MARIE JOSEPHINE CORDERO banks and insurance companies for their regular transactions. These businesses authorized by the BIR
SOLANO A.K.A. MA. JOSEPHINE S. CABAÑEZ, may load documentary stamps on their DS metering machine in accordance with the rules and
Respondent. regulations. In other words, this system allows advanced payment of the DST for future applications.
G.R. No. 207811, June 01, 2016 - PEOPLE OF THE However, for purposes of determining the prescriptive period for a claim for a refund or tax credit, this
PHILIPPINES, Plaintiff-Appellee, v. DELIA MOLINA Y
Court finds it imperative to emphasize the nature of the DST.
CABRAL, Accused-Appellants.
G.R. No. 182537, June 01, 2016 - MACTAN-CEBU In Gibbs v. Commissioner of Internal Revenue,12 this Court ruled that "[p]ayment is a mode of
INTERNATIONAL AIRPORT AUTHORITY, Petitioner, v. extinguishing obligations (Art. 1231, Civil Code) and it means not only the delivery of money but also the
RICHARD E. UNCHUAN, Respondent. performance, in any other manner, of an obligation. A taxpayer, resident or non-resident, does so not
really to deposit an amount to the Commissioner of Internal Revenue, but, in truth, to perform and
G.R. No. 187462, June 01, 2016 - RAQUEL G. KHO, extinguish his tax obligation for the year concerned. In other words, he is paying his tax liabilities for
Petitioner, v. REPUBLIC OF THE PHILIPPINES AND that year. Consequently, a taxpayer whose income is withheld at source will be deemed to have paid his
VERONICA B. KHO, Respondents.
tax liability when the same falls due at the end of the tax year. It is from this latter date then, or when
the tax liability falls due, that the two-year prescriptive period under Section 306 (now part of Section
G.R. No. 206419, June 01, 2016 - PEOPLE OF THE
PHILIPPINES, Plaintiff-Appellee, v. RUBEN DELA
230) of the Revenue Code starts to run with respect to payments effected through the withholding tax
ROSA, Accused-Appellant. system." The aforequoted ruling presents two alternative reckoning dates: (1) the end of the tax year;
and (2) the date when the tax liability falls due.13chanrobleslaw
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
G.R. No. 202047, June 08, 2016 - LIGHT RAIL Applying the same rationale to this case, the payment of the DST and the filing of the DST Declaration
TRANSIT AUTHORITY, Petitioner, v. NOEL B. PILI, Return upon loading/reloading of the DS metering machine must not be considered as the "date of
MEDEL I. LIRIO, RODERICK B. JAMON, VICTORINO A. payment" when the prescriptive period to file a claim for a refund/credit must commence. For DS
MACHICA, RONNIE C. VALORIA, VIRGILIO M. FLORES, metering machine users, the payment of the DST upon loading/reloading is merely an advance payment
RENATO C. PALMA, ANGELITO V. GUINTO, RAMIRO M.
for future application. The liability for the payment of the DST falls due only upon the occurrence of a
FELICIANO, ENRIQUE L. CIUBAL, ELMER P. TABIGAN,
taxable transaction. Therefore, it is only then that payment may be considered for the purpose of filing a
VENANCIO T. MADRIA, MAXIMO M. VITANGCOL,
RODOLFO L. PAGUIO, ARNEL F. MAGSALIN, JULIANA
claim for a refund or tax credit. Since actual payment was already made upon loading/reloading of the
N. DOLOR, NOEL C. CRUZ, SANDY C. JARILLA, BERTITO DS metering machine and the filing of the DST Declaration Return, the date of imprinting the
I. SERVIDAD, ALAN R. CORPUZ, ROBERT D. PABLO, documentary stamp on the taxable document must be considered as the date of payment contemplated
ROBERT H. MONTEREY, HENRY L. LIAO, ROLANDO C. under Section 229 of the NIRC.
CEBANICO, VELIENTE S. FANTASTICO, MA. EMILIAN S.
CRUZ, EDGARDO G. GAMBAYAN, GERARDO M. This interpretation is more logical and consistent with Section 200 (D) that "the tax may be paid xxx by
RUMBAWA, DANTE D. PALOMARA, MA. TERESA B. DE imprinting the stamps through a documentary stamp metering machine, on the taxable document, in the
LOS REYES, JOSE ALLAN S. PACIFICO, RESTITUTO R. manner as may be prescribed by rules and regulations to be promulgated by the Secretary of Finance,
MALAPO, EARL G. PONGCO, LUCILO C. DEL MONTE, upon recommendation of the Commissioner." The policies issued by the Secretary of Finance were made
RUEL F. MAGBALANA, MARLYN V. VILLANUEVA, to regulate the use of the DS metering machine, but they cannot be interpreted to limit the prescriptive
JUDITH C. BANEZ, GERMAN N. DE LUNA, FREDERICK B.
period for claims for a refund. In fact, the details attached to the DST Declaration Return are those of
DEL CORRO, CLODUALDO B. PASIOLAN, ROLANDO I.
usage or consumption of the DST from the previous purchase. It is in effect a final return of the DST
NAVARRO, AND PACIANO J. VILLANUEVA,*,
Respondents.
previously purchased, but advances the payment for the new purchase. Thus, to cure the ambiguity
caused by the uniqueness of this system, we must bear in mind the nature of the tax for the purpose of
G.R. No. 211026, June 27, 2016 - PEOPLE OF THE determining prescription.
PHILIPPINES, Plaintiff-Appellee, v. RENATO B.
SUEDAD, Accused-Appellant. Applying the foregoing to this case, the DST fell due when petitioner entered into repurchase agreements
with the BSP and the corresponding documentary stamps were imprinted on the Confirmation Letters.
G.R. No. 204441, June 08, 2016 - PEOPLE OF THE Considering, however, that this transaction is exempt from tax, petitioner is entitled to a refund. The
PHILIPPINES, Petitioner, v. MICHAEL KURT JOHN prescriptive period for the filing of a claim for a refund or tax credit under Section 229 must be reckoned
BULAWAN Y ANDALES, Respondent. from the date when the documentary stamps were imprinted on the Confirmation Letters.
G.R. No. 201834, June 01, 2016 - ANDRES L.
Consequently, the CTA Division's counting of the prescriptive period from the date when the
DIZON, Petitioner, v. NAESS SHIPPING PHILIPPINES,
documentary stamps were imprinted on the Confirmation Letters of the repurchase agreements is more
INC. AND DOLE UK (LTD.), Respondents.
in accord with the rationale of Section 229. Since we also find that the evidence presented by petitioner
G.R. No. 196962, June 08, 2016 - PEOPLE OF THE was carefully considered, we find no reason to overturn the factual finding of the CTA Division.
PHILIPPINES, Plaintiff-Appellee, v. JOAN SONJACO Y Accordingly, the Decision in C.T.A. Case No.7486 dated 13 July 200914 must be reinstated.
STA. ANA, Accused-Appellant.
WHEREFORE, premises considered, the Petition is PARTLY GRANTED. The CTA en banc Decision dated
G.R. No. 191936, June 01, 2016 - VIRGINIA D. 13 May 2010 and Resolution dated 14 October 2010 in C.T.A. EB Nos. 555 and 556 are hereby SET
CALIMAG, Petitioner, v. HEIRS OF SILVESTRA N. ASIDE, and the Decision in C.T.A. Case No.7486 dated 13 July 2009 is REINSTATED.
MACAPAZ, REPRESENTED BY ANASTACIO P. MACAPAZ,
JR., Respondents.
SO ORDERED.chanRoblesvirtualLawlibrary
G.R. No. 193374, June 08, 2016 - HEIRS OF THE
LATE GERRY* ECARMA, NAMELY: AVELINA SUIZA-
Leonardo-De Castro, Bersamin, Perlas-Bernabe, and Caguioa, JJ., concur.
ECARMA, DENNIS ECARMA, JERRY LYN ECARMA PENA,
ANTONIO ECARMA AND NATALIA ECARMA
Endnotes:
SANGALANG, Petitioners, v. COURT OF APPEALS AND
RENATO A. ECARMA, Respondents.
1Rollo, pp. 17-38.
G.R. No. 175592, June 14, 2016 - PEOPLE OF THE
PHILIPPINES, Plaintiff-Appellee, v. EDISON C. 2 Id. at 43-66; penned by Associate Justice Esperanza R. Fabon-Victorino and concurred in
MAGBITANG, Accused-Appellant. by then Presiding Justice Ernesto D. Acosta, Associate Justices Juanito C. Castañeda Jr.,
Lovell R. Bautista, Erlinda P. Uy, and Olga Palanca-Enriquez.
G.R. No. 174838, June 01, 2016 - STRONGHOLD
INSURANCE CO., INC., Petitioner, v. PAMANA ISLAND 3
RESORT HOTEL AND MARINA CLUB, INC., Respondent.
Id. at 67-77.
4 Id. at 93-112; CTA Second Division Decision dated 13 July 2009, penned by Associate
G.R. No. 185331, June 08, 2016 - SPOUSES
ABELARDO VALARAO AND FRANCISCA VALARAO, Justice Erlinda P. Uy and concurred in by Associate Justices Juanito C. Castafieda, Jr. and
Petitioners, v. MSC AND COMPANY, Respondent. Olga Palanca-Enriquez.
G.R. No. 205097, June 08, 2016 - CORAZON D. 5 An Act Rationalizing the Provisions on the Documentary Stamp Tax of the National
ISON, Petitioner, v. PEOPLE OF THE PHILIPPINES,
Internal Revenue Code of 1997, as amended, and for other purposes.
Respondent.
6 Supra note 2.
G.R. No. 211212, June 08, 2016 - SUN LIFE OF
CANADA (PHILIPPINES), INC., Petitioner, v. MA.
DAISY'S. SIBYA, JESUS MANUEL S. SIBYA III, JAIME 7 SEC. 229. Recovery of Tax Erroneously or Illegally Collected. — No suit or proceeding
LUIS S. SIBYA, AND THE ESTATE OF THE DECEASED shall be maintained in any court for the recovery of any national internal revenue tax
ATTY. JESUS SIBYA, JR., Respondents. hereafter alleged to have been erroneously or illegally assessed or collected, or of any
penalty claimed to have been collected without authority, or of any sum alleged to have
G.R. No. 208646, June 15, 2016 - PEOPLE OF THE
been excessively or in any manner wrongfully collected, until a claim for refund or credit
PHILIPPINES, Plaintiff-Appellee, v. LORETO SONIDO Y
CORONEL, Accused-Appellant.
has been duly filed with the Commissioner; but such suit or proceeding may be
maintained, whether or not such tax, penalty, or sum has been paid under protest or
G.R. No. 207517, June 01, 2016 - PEOPLE OF THE duress.
PHILIPPINES, Appellee, v. RAUL AMARO Y CATUBAY
ALIAS "LALAKS," Appellant. In any case, no such suit or proceeding shall be filed after the expiration of two (2)
years from the date of payment of the tax or penalty regardless of any
G.R. No. 200081, June 08, 2016 - PEOPLE OF THE supervening cause that may arise after payment: Provided, however, That the
PHILIPPINES, Plaintiff-Appellee, v. EDGARDO T. CRUZ, Commissioner may even without a written claim therefor, refund or credit any tax, where
Accused-Appellant. on the face of the return upon which payment was made, such payment appears clearly to
have been erroneously paid. (Emphasis supplied)
G.R. No. 194605, June 14, 2016 - PEOPLE OF THE
PHILIPPINES, Plaintiff-Appellee, v. MARIANO 8
OANDASAN, JR., Accused-Appellant. SEC. 200. Payment of Documentary Stamp Tax. -
G.R. No. 214440, June 15, 2016 - PEOPLE OF THE (A) In General. - The provisions of Presidential Decree No. 1045 notwithstanding, any
PHILIPPINES, Plaintiff-Appellee, v. ALEX MENDEZ person liable to pay documentary stamp tax upon any document subject to tax under Title
RAFOLS, Accused-Appellant. VII of this Code shall file a tax return and pay the tax in accordance with the rules and
regulations to be prescribed by the Secretary of Finance, upon recommendation of the
G.R. No. 217732, June 15, 2016 - EMILIO S. Commissioner.
AGCOLICOL, JR., Petitioner, v. JERWIN CASIÑO,
Respondent. (B) Time for Filing and Payment of the Tax. - Except as provided by rules and regulations
promulgated by the Secretary of Finance, upon recommendation of the Commissioner, the
G.R. No. 172352, June 08, 2016 - LAND BANK OF
tax return prescribed in this Section shall be filed within ten (10) days after the close of
THE PHILIPPINES, Petitioner, v. ALFREDO HABABAG,
SR., SUBSTITUTED BY HIS WIFE, CONSOLACION, AND
the month when the taxable document was made, signed, issued, accepted, or
CHILDREN, NAMELY: MANUEL, SALVADOR, WILSON, transferred, and the tax thereon shall be paid at the same time the aforesaid return is
JIMMY, ALFREDO, JR., AND JUDITH, ALL SURNAMED filed.
HABABAG, Respondents.; G.R. NOS. 172387-88 -
ALFREDO HABABAG, SR., SUBSTITUTED BY HIS WIFE, (C) Where to File. - Except in cases where the Commissioner otherwise permits, the
CONSOLACION, AND CHILDREN, NAMELY: MANUEL, aforesaid tax return shall be filed with and the tax due shall be paid through the
SALVADOR, WILSON, JIMMY, ALFREDO, JR., AND authorized agent bank within the territorial jurisdiction of the Revenue District Office which
JUDITH, ALL SURNAMED HABABAG, Petitioners, v. has jurisdiction over the residence or principal place of business of the taxpayer. In places
LAND BANK OF THE PHILIPPINES AND THE where there is no authorized agent bank, the return shall be filed with the Revenue
DEPARTMENT OF AGRARIAN REFORM, Respondent. District Officer, collection agent, or duly authorized Treasurer of the city or municipality in
which the taxpayer has his legal residence or principal place of business.
G.R. No. 215994, June 06, 2016 - OFFICE OF THE
OMBUDSMAN AND FIELD INVESTIGATION OFFICE,
Petitioner, v. ROLANDO B. FALLER, Respondent.
(D) Exception. - In lieu of the foregoing provisions of this Section, the tax may be
paid either through purchase and actual affixture; or by imprinting the stamps
A.C. No. 11069, June 08, 2016 - RONALDO C. through a documentary stamp metering machine, on the taxable document, in
FACTURAN, Complainant, v. PROSECUTOR ALFREDO L. the manner as may be prescribed by rules and regulations to be promulgated by
BARCELONA, JR., Respondent. the Secretary of Finance, upon recommendation of the Commissioner. (Emphasis
supplied)
G.R. No. 208475, June 08, 2016 - PEOPLE OF THE
PHILIPPINES, Plaintiff-Appellee, v. MANUEL 9 Dated 31 January 1997.
REBANUEL Y NADERA, Accused-Appellant.
10Commissioner of Internal Revenue v. First Express Pawnshop Co., Inc., 607 Phil. 227
G.R. No. 168749, June 06, 2016 - SUGARSTEEL
INDUSTRIAL, INC. AND MR. BEN YAPJOCO, (2009).
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
Petitioners, v. VICTOR ALBINA, VICENTE UY AND ALEX
VELASQUEZ, Respondents. 11Commissioner of Internal Revenue v. TMX Sales, Inc., G.R. No. 83736, 15 January
1992, 205 SCRA 184; Philippine Bank of Communications v. Commissioner of Internal
G.R. No. 160071, June 06, 2016 - ANDREW D. FYFE,
Revenue, 361 Phil. 916 (1999); ACCRA Investments Corp. v. Court of Appeals, G.R. No.
RICHARD T. NUTTALL, AND RICHARD J. WALD,
Petitioners, v. PHILIPPINE AIRLINES, INC.,
96322, 20 December 1991, 204 SCRA 957.
Respondent.
12 122 Phil. 714 (1965).
G.R. No. 217943, June 06, 2016 - J. MELLIZA
ESTATE DEVELOPMENT COMPANY, INC., 13ACCRA Investments Corp. v. Court of Appeals, supra.
REPRESENTED BY ITS DIRECTOR, ATTY. RAFAEL S.
VILLANUEVA, Petitioner, v. ROSENDO SIMOY, 14Rollo,
GREGORIO SIMOY AND CONSEJO SIMOY,
pp. 93-112.
Respondents.
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
Petitioners, v. HEIRS OF CATAMANAN MAMA,
REPRESENTED BY HASAN MAMA, Respondents.
A.C. No. 9871, June 29, 2016 - IN RE: A.M. NO. 04-
7-373-RTC [REPORT ON THE JUDICIAL AUDIT
CONDUCTED IN THE REGIONAL TRIAL COURT,
BRANCH 60, BARILI, CEBU] AND A.M. NO. 04-7-374-
RTC [VIOLATION OF JUDGE ILDEFONSO SUERTE,
REGIONAL TRIAL COURT, BRANCH 60, BARILI, CEBU
OF ADMINISTRATIVE ORDER NO. 36-2004 DATED
MARCH 3, 2004], PROSECUTOR MARY ANN T. CASTRO-
ROA, Respondent.
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
G.R. No. 194235, June 08, 2016 - PEOPLE OF THE
PHILIPPINES, Plaintiff-Appellee, v. JAY GREGORIO Y
AMAR @ "JAY," ROLANDO ESTRELLA Y RAYMUNDO @
"BONG," DANILO BERGONIA Y ALELENG @ "DANNY,"
EFREN GASCON Y DELOS SANTOS @ "EFREN,"
RICARDO SALAZAR Y GO @ "ERIC," AND JOHN DOE,
Accused-Appellants.
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
TERESITA PINEDA DELFIN, ESTER R. PINEDA, FE Y.
UZON, PACENCIA ERFE VERSOZA, IMPRESSION V.
CLEMENTE, ALL REPRESENTED BY DELFIN R. PINEDA,
ATTORNEY-IN-FACT, Respondents.; SPOUSES
ARNULFO R. VERSOZA AND PRISCILLA M. VERSOZA;
SPOUSES DOMINGO AND DOMINGA GOMEZ; AND
ERLINDA GOMEZ-OCAY, IN HER BEHALF AND IN
BEHALF OF CARLITO, MEDELINA, ANGELISTA,
SILVERA, LOLITA, & ROMBERTO, ALL SURNAMED
GOMEZ, Intervenor-Respondents.
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
DUMONT, Petitioner, v. MARIA REMEDIOS ANG,
Respondent.
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23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
DAMASING AND POTENCIANA LABIA, SPOUSES
FRANCISCO AND SIMPLICIA BABAYA-ON, SPOUSES
RUFINO BUTIHIN AND CECILIA CAGNO, SPOUSES
EFITACIO G. PAMISA AND VIRGELIA VIRTUDAZO,
DELFIN B. SARINAS, SPOUSES FELIPE C. VIRTUDAZO,
JR. AND GRACE TUTO, SPOUSES ANGEL BARBOSA AND
FLORENCIA SALISE, SPOUSES FRANKLIN AND
LEONORA PAMISA, SPOUSES MARCELO MANIQUE AND
CECILIA CARBON, LARRY PAMISA, SPOUSES ENRIQUE
CARBON AND ERLINDA SOMO, SPOUSES WILFREDO A.
JUANILO AND MINDA VILLARMIA, SPOUSES FELIX
REQUILME AND CERINA SALVO, SPOUSES CARLITO
FABE AND EMELITA MANGGANA, LUIBEN MAGTO,
SPOUSES SERAFIN AND LILIA SURIGAO, SPOUSES
HILARIO BACABIS AND RETIFICACION DABLO,
SPOUSES REYNALDO S. SALUCOT AND ANECITA
DESCALLAR, SPOUSES HAGENIO PAUG AND EVELITA
VIRTUDAZO, SPOUSES MAXIMO BORREZ AND VILMA
SALISE, SPOUSES FELIMON V. SALVO, JR., EVA
MACATOL AND RITA V. SALVO, Petitioners, v.
DEPARTMENT OF AGRARIAN REFORM ADJUDICATION
BOARD REGION X ADJUDICATOR ABETO SALCEDO, JR.
AND RICARDO GACULA, Respondents.
http://www.chanrobles.com/cralaw/2016junedecisions.php?id=547 9/10
23/02/2018 G.R. No. 194065, June 20, 2016 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. COMMISSIONER OF INTERNAL REVENU…
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