TAXATION LAW

I. General Principles

A. Power of Taxation as Distinguished from Police Power and Eminent Domain

TAXATION POLICE POWER EMINENT DOMAIN

As to Purpose
To promote general
To generate revenues for To promote public welfare welfare by the taking of
the State through regulations private property for
public use
As to Amount of Exaction
No exaction;
Limited only to cover cost just compensation is
No limit as to the amount
of regulation, issuance of paid based on the fair
due as taxes
license or surveillance market value of the
private property taken
As to Benefits Received
Promotion of general
welfare and protection of
public interest;
damnum absque Benefit in the form of
No direct benefit to the injuria (Latin for "loss or just compensation
taxpayer damage without injury"); a received by the property
person (natural or juridical) owner
causes damage or loss to
another, but does not injure
them.
As to the application of the rule on
Non-Impairment of Contracts
Not applicable as
Not applicable as contracts
Applies in Taxation contracts may be
may be impaired
impaired
As to the Transfer of Property Rights
No transfer of property;
Ownership over the
Taxes paid form part of only restraint in the
property expropriated is
public funds exercise of property rights
transferred to the State
exist
As to Scope
Affects only the
Affects all persons, Affects all persons,
particular property
properties and excises properties and excises
subject of expropriation

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 As to Basis of Imposition
Promotion of common
good; the right of the State Public need; the taking
Public Necessity –
and the public to self- of private property is for
Lifeblood Doctrine
protection and public purpose
preservation

B. Inherent and Constitutional Limitations of Taxation

1. Inherent Limitations
a) Situs or Territoriality
1) Factors that determine situs of income
a. Nationality or citizenship of taxpayer (Sec 23 NIRC)
b. Residence or domicile of taxpayer (Estate and Donor’s
taxation)
c. Source of Income (Sec 42, NIRC)
d. Location of Property (Capital gains)
e. Place or exercise of privilege (Sec 42, NIRC)
f. Classification of the tax being levied (ordinary v. capital
asset; tangible v. intangible properties)

b) Public Purpose
1) Tests in determining Public Purpose
a. Duty Test – something which is the duty of the State as
a government to appropriate
b. General Welfare Test – the imposition will promote the
welfare of the community in equal measure
c) International Comity – the property of a foreign state / government
may not be taxed by another state
1) Sovereign equality among States – equals have no Sovereignty
over each other (Par in parem non habet imperium)
2) Usage among States – when one enters the territory of
another, there is an implied understanding that the former
does not intend to degrade its dignity by placing itself under
the jurisdiction of the latter.
3) Foreign Governments may not be sued without its consent –
assessed taxes cannot be collected
d) Non-delegability or Legislative Nature
1) Exceptions:
a. Delegation to Local Government Units – each LGU shall
have the power to create its own sources of revenues,
subject to limitation by law (Art X. Sec 5, 1987
Philippine Constitution)
b. Delegation to the President –
i. to fix tariff rates, import and export quotas,
tonnage and wharfage dues, and other duties
or imposts within the framework of the national
development program of the Government (Art
VI. Sec 28(2))

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 ii. No treaty or international agreement (entered
into by the President) shall be valid and effective
unless concurred in by at least two-thirds of all
the Members of the Senate. (Art VII. Sec 21)

e) Exemption of Government from taxes

1) Agencies performing governmental functions are tax-exempt
2) Agencies performing proprietary functions are taxable
a. GOCCs subject to tax at the rate imposed on
corporations engaged in a similar business, industry or
activity except GSIS, SSS, PHIC, and local water districts
Sec 27 (C), NIRC

2. Constitutional Limitations
a) Directly affecting taxation
1) No person shall be imprisoned for debt or non-payment of a
poll tax. Art III. Sec 20
2) The rule of taxation shall be uniform and equitable. The
Congress shall evolve a progressive system of taxation. Art VI.
28[1))
3) The Congress may, by law, authorize the President to fix within
specified limits, and subject to such limitations and restrictions
as it may impose, tariff rates, import and export quotas,
tonnage and wharfage dues, and other duties or imposts within
the framework of the national development program of the
Government. (Art VI. Sec 28[2))
4) Charitable institutions, churches and personages or convents
appurtenant thereto, mosques, non-profit cemeteries, and all
lands, buildings, and improvements, actually, directly, and
exclusively used for religious, charitable, or educational
purposes shall be exempt from taxation. (Art VI. Sec 28[3))
5) No treaty or international agreement shall be valid and effective
unless concurred in by at least two-thirds of all the Members of
the Senate. (Art VII. Sec 21)
6) No public money or property shall be appropriated, applied,
paid, or employed, directly or indirectly, for the use, benefit, or
support of any sect, church, denomination, sectarian
institution, or system of religion, or of any priest, preacher,
minister, other religious teacher, or dignitary as such, except
when such priest, preacher, minister, or dignitary is assigned to
the armed forces, or to any penal institution, or government
orphanage or leprosarium. (Art VII. Sec 29[2])
7) All money collected on any tax levied for a special purpose shall
be treated as a special fund and paid out for such purpose only.
If the purpose for which a special fund was created has been
fulfilled or abandoned, the balance, if any, shall be transferred
to the general funds of the Government. (Art VII. Sec 29[3])

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 8) All revenues and assets of non-stock, non-profit educational
institutions used actually, directly, and exclusively for
educational purposes shall be exempt from taxes and duties.
Upon the dissolution or cessation of the corporate existence of
such institutions, their assets shall be disposed of in the manner
provided by law.
a. Proprietary educational institutions, including those
cooperatively owned, may likewise be entitled to such
exemptions, subject to the limitations provided by law,
including restrictions on dividends and provisions for
reinvestment. (Art XIV. Sec 4[3])
9) Subject to conditions prescribed by law, all grants,
endowments, donations, or contributions used actually,
directly, and exclusively for educational purposes shall be
exempt from tax. (Art XIV. Sec 4[4])
10) The Congress may provide for incentives, including tax
deductions, to encourage private participation in programs of
basic and applied scientific research. Scholarships, grants-in-
aid, or other forms of incentives shall be provided to deserving
science students, researchers, scientists, inventors,
technologists, and specially gifted citizens. (Art XIV. Sec 11)

b) Provisions indirectly affecting taxation

1) No person shall be deprived of life, liberty, or property without
due process of law, nor shall any person be denied the equal
protection of the laws (Art III. Sec 1)
a. Requisites for valid classification
i. The classification is based on Substantial
Distinction
ii. It must be Germane to the purpose of the law
iii. It must apply to both present and future
conditions; not limited to current circumstances
iv. It must apply equally to all members belonging
to the same class
2) No law shall be passed abridging the freedom of speech, of
expression, or of the press, or the right of the people peaceably
to assemble and petition the government for redress of
grievances (Art III. Sec 4)
3) No law shall be made respecting an establishment of religion,
or prohibiting the free exercise thereof. The free exercise and
enjoyment of religious profession and worship, without
discrimination or preference, shall forever be allowed. No
religious test shall be required for the exercise of civil or political
rights. (Art III. Sec 5)
4) No law impairing the obligation of contracts shall be passed (Art
III. Sec 10)

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C. Requisites of a Valid Tax
1. It must be for a public purpose
2. It must be uniform
3. The party being taxed must be within the jurisdiction of the taxing authority
4. The tax must not impugn on the inherent and constitutional limitations on
the power of taxation
5. Assessment and collection of certain kinds of taxes shall observe the rules on
due process to safeguard against injustice to taxpayers
D. Tax as Distinguished from Other Forms of Exactions

TAX TARIFF TOLL LICENSE

General term for all
A kind of tax An amount charged Amount imposed
kinds of forced
imposed on articles for the cost and for regulation;
contributions on
which are traded maintenance of the limited to cost of
persons for public
internationally property used issuing license
purpose

SPECIAL ASSESSMENT (LEVY)

Levied only on land; generally, not for
revenue generation but for recovery of
cost of improvements incurred by the
government based on benefits received
by the property

TAX DEBT
An obligation imposed by law Incurred based on contract
Payable to the government in its Due to the government acting in its
sovereign capacity corporate facility
Generally, not subject to compensation Subject to legal compensation under
the Civil Code

E. Kinds of Taxes
1. As to Object
a) Personal Tax – otherwise known as “capitation” or “poll” tax. A
fixed amount imposed on persons within the jurisdiction of the
taxing power without regard to the amount of their property or
occupation or business they may be engaged in
b) Property Tax – tax on properties within the jurisdiction of the taxing
authority
c) Privilege (Excise) Tax – imposed on the performance of an act,
engaging in an occupation or enjoyment of a privilege

2. As to Burden or Incidence
a) Direct Tax – imposed on the person intended by law to pay the tax;
both the statutory and economic burden shall be borne by the same
person (e.g. Income Tax, Percentage Tax, Estate and Donor’s taxes)

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 b) Indirect Tax – statutory burden is imposed on a person while the
economic burden for the tax is shifted to another (VAT, excise taxes
3. As to Tax Base
a) Specific Tax -based on physical unit of measure e.g. per head or
number, weight, length or volume
b) Ad Valorem Tax – based on value of the property subject of taxation
c) Mixed – partially specific and partially ad valorem; e.g. excise tax on
fermented liquors (ad valorem tax x net retail price plus specific tax
per proof liter)
4. As to purpose
a) General Tax – levied for ordinary and general purpose of
government
b) Special Tax – imposed to achieve some social or economic end (e.g.
Special Education Fund [Sec 235, LGC], OPSF [Lozano v. ERB, GR No.
95119 December 21, 1990], Margin Fees [Esso Standard Eastern v.
CIR, GR No. 28608, July 9, 1989])
5. As to Scope or Authority to Impose
a) National – levied by the National Government through Congress
b) Local – levied by local government units through its local tax
ordinances
6. As to Gradation
a) Progressive – the rate of tax increases as the taxable income
increases; based on taxpayer’s capacity to pay; Theoretical justice
applied
b) Regressive – single tax rate such as VAT which is indifferent to the
taxpayer’s capacity to pay; the same tax is paid by both affluent and
marginalized income earners on the same product (e.g. VAT on
groceries, dine in food purchased from restaurants)

F. Doctrines in Taxation
1. Construction and Interpretation of Tax Laws, Rules, and Regulations
a) General Rule – when the law is clear, there is no necessity to
interpret or construe its provisions; thus it must be applied as
expressed in the statute.
b) Exception – in case of doubtful or ambiguous provisions:
1) Tax Statutes are construed or interpreted strictly against the
taxing authority and liberally in favor of the taxpayer; Any
ambiguity in a tax statute shall favor the taxpayer inasmuch as
tax being a forced contribution essentially is a deprivation of the
taxpayer’s property rights.
2) Provision in the statute granting Tax exemptions, exclusions,
deductions are construed strictly against the party claiming the
same and interpreted liberally in favor of the taxing authority.
c) Interpretation of Tax rules and regulations –
The general principles in the construction of tax laws applies in the
interpretation of tax rules and regulations. To be valid, the tax rules

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 must be consistent with the provisions of the tax law which they seek
to implement.
1) Requisites for a valid tax regulation
a. Publication
b. Germane to the public purpose of the tax statute
c. Exercised with authority as provided in the statute
2) Non-retroactive application (Sec 246, NIRC)
a. Any revocation, modification or reversal of any of the
rules and regulations promulgated in accordance with
the preceding Sections or any of the rulings or circulars
promulgated by the Commissioner shall not be given
retroactive application IF the revocation, modification
or reversal will be prejudicial to the taxpayers, EXCEPT
in the following cases:
i. Where the taxpayer deliberately misstates or
omits material facts from his return or any
document required of him by the Bureau of
Internal Revenue;
ii. Where the facts subsequently gathered by the
Bureau of Internal Revenue are materially
different from the facts on which the ruling is
based; or
iii. Where the taxpayer acted in bad faith.

2. Prospectivity of Tax Laws

a) General Rule – Tax Laws are prospective in application
b) Exceptions –
1) Where no vested rights will be impaired
2) Where the law allows retroactive application; and
3) If there is bad faith on the part of the taxpayer
3. Imprescriptibility of Taxes
a) General Rule – Taxes are imprescriptible
b) Exceptions –
1) When the law provides for prescription – Sec 203 and 222 of
the NIRC, Sec 194 and 270, LGC; CIR v. Ayala Securities Corp, GR
L-29485, 21 Nov 1989
4. Double Taxation – means taxing the same person twice when he / she / it
should only be taxed once
a) Double Taxation in its Strict Sense (Direct Duplicate Taxation) –
violates the equal protection clause of the constitution
Requisites:
1) Both taxes are imposed on the same person or property or
subject matter
2) For the same purpose
3) Imposed by the same taxing authority
4) Within the same jurisdiction
5) During the same taxable period

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 6) Covering the same kind or character of tax

b) Double Taxation in its Broad Sense (Indirect Duplicate Taxation) –

not legally objectionable; The absence of one or more of the above
requisites for direct duplicate taxation makes it indirect.
c) Is Double Taxation unconstitutional? Our Constitution does not
expressly prohibit double taxation; however, the imposition may be
invalidated if it results in the violation of the equal protection or due
process clause of the Constitution.
d) Modes of minimizing the effects of Double Taxation (Indirect)
1) Tax Deduction – applied against gross income to reduce taxable
income
2) Tax Credit – the amount paid as tax is charged directly against
the tax due

Tax Credit v Tax Deduction – a tax credit is charged against the

tax due which allows the claimant to obtain 100% tax benefit
while a tax deduction only reduces the tax base (taxable
income) which will only result to a tax benefit equal to the tax
rate applied against the amount claimed as a deduction

3) Treaties with other States

A tax treaty sets out the respective rights to tax of the State of
Source (situs) and the state of residence with regard to certain
cases, where an exclusive right to tax is conferred on one of the
contracting States; however, for other items of income or
capital, both States are given the right to tax, although the
amount of tax that may be imposed by the State of Source is
limited. This applies whenever the State of Source is given full
or limited right to tax. The treaty makes it incumbent upon the
State of Residence to allow relief in order to minimize the
effects of double taxation.

4) Tax Exemption – a grant of immunity, express or implied, to

particular persons or entities from the obligation to pay taxes.

5. Escape from Taxation

a) Shifting of Tax Burden – the transfer of the burden for the tax by the
original payer or the one identified under the tax statute to be liable
for the tax e.g. Sec 105, NIRC
1) Forward Shifting – transfer of the tax burden from a factor of
production through the factors of distribution until finally rests
on the consumer
2) Backward Shifting – transfer of the tax burden from the
consumer through the factors of distribution to the factors of
production

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 3) Onward Shifting – transfer of the tax burden two or more
times either forward or backward
b) Tax Avoidance – means used by the taxpayer which are legally
permissible; use of alternative tax rates or methods of assessing
taxable property or income in order to avoid or reduce tax liability
(ex. Sec 40(C)(2) on tax free exchange, Sec 24(D)(2) on sale of
principal place of residence)
c) Tax Evasion – use by the taxpayer of illegal or fraudulent means to
evade or lessen the payment of a tax (CIR v. Benigno Toda G.R. No.
147188, September 14, 2004)
1) Instances to illustrate indicia of Fraud in Tax Evasion
a. Failure to declare for taxation purposes true and actual
income derived from business for 2 consecutive years;
b. Substantial under-declaration of revenues in the
income tax returns of the taxpayer for 4 consecutive
years coupled with intentional overstatement of
deductions; See Sec 115(a)(3), NIRC on understatement
of sales
2) Factors to determine Fraud
a. The end to be achieved, i.e. the payment of less than
the amount known by the taxpayer to be legally due;
b. An accompanying state of mind which is described as
being “evil”, in “bad faith”, “willful” or “deliberate and
not merely accidental”; and
c. A course of action or failure of action which is unlawful
6. Exemption from Taxation
a) Nature –
1) It is a personal privilege of the grantee
2) It is generally revocable by the government unless the
exemption is founded on a contract, which is protected from
impairment, but the contract must contain the other essential
elements of a valid contract; It implies a waiver on the part of
the government to collect what otherwise would be due, and
in this sense is prejudicial thereto.
3) It is not necessarily discriminatory so long as the exemption
has a reasonable foundation, rationale or basis.
7. Equitable Recoupment
Where the refund of a tax illegally or erroneously collected or overpaid by a
taxpayer is barred by prescription, a tax being assessed against a taxpayer
may be recouped or set-off against the tax whose refund is now barred by
prescription. (UST v. Collector, 104 Phil 1062)
8. Prohibition on Compensation and Set-Off – Taxes cannot be the subject of
compensation or set-off
a) Reasons –
1) Lifeblood Doctrine -the government needs funds to sustain its
operations rendering essential services to the public

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 2) Taxes are not contractual obligations but arise out of duty to
the government
3) The government and the taxpayer are not mutually creditors
and debtors of each other (Francia v. IAC, GR No. 67649, June
28, 1988)
4) Exemption – where both claims already became due and
demandable and fully liquidated; or where the government
and the taxpayer are in their own rights reciprocally debtors
and creditors of each other, compensation takes place by
operation of law. (Domingo v. Garlitos G.R. No. L-18994, June
29, 1963)
9. Compromise and Tax Amnesty
a) A compromise is a contract whereby the parties, by making
reciprocal concessions, avoid a litigation or put an end to one
already commenced (Art 2028, Civil Code); Tax Amnesty is the
general or intentional overlooking by the State of its authority to
impose penalties on persons otherwise guilty of evasion or violation
of a revenue or tax law. It partakes of an absolute forgiveness or
waiver of the government of its right to collect. To give tax evaders,
who wish to relent and are willing to reform, a chance to start with
a clean slate. (CIR v. Philippine Aluminum Wheels, Inc. GR No.
216161, August 9, 2017)
b) Amnesty v. Exemption - Tax Amnesty grants immunity from all
criminal, civil and administrative obligations arising from non-
payment of taxes. It is a general pardon given to all taxpayers. It
applies only to past tax periods, hence of retroactive application.
(People v. Castaneda, GR No. L-46881, September 15, 1988); Tax
Exemption grants immunity only for civil liabilities. It is an immunity
or privilege, a freedom from charge or burden of which others are
subjected. It is generally prospective in application (Florer v.
Sheridan, 137 Ind 28, 36 NE 365)
c) Requisites:
1) The taxpayer must have a tax liability
2) There must be an offer (of the amount to be paid by the
taxpayer)
3) There must be an acceptance (by the CIR or taxpayer, as the
case may be) of the offer in the settlement of the original
claim.
d) Persons allowed to enter into Compromise of tax obligations
1) Commissioner of Internal Revenue – Section 204 (A), NIRC on
grounds of doubtful validity of the assessment or financial
incapacity of the taxpayer
2) Commissioner of Customs – Section 201, CMTA, subject to
approval of the Secretary of Finance, in cases involving the
imposition of fines, surcharges and forfeitures.

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II. National Taxation

A. Taxing Authority
1. Jurisdiction, Power, and Functions of the Commissioner of Internal Revenue
e) Interpreting Tax Laws and Deciding Tax Cases
f) Non-Retroactivity of Rulings
2. Rule-Making Authority of the Secretary of Finance
B. Income Tax
1. Definition, Nature, and General Principles
a) Criteria in Imposing Philippine Income Tax
b) Types of Philippine Income Taxes
c) Taxable Period
d) Kinds of Taxpayers
2. Income
a) Definition and Nature
b) When Income is Taxable
c) Tests in Determining Whether Income is Earned for Tax Purposes
(1) Realization Test
(2) Economic Benefit Test, Doctrine of Proprietary Interest
(3) Severance Test
d) Tax-Free Exchanges
e) Situs of Income Taxation
3. Gross Income
a) Definition
b) Concept of Income from Whatever Source Derived
c) Gross Income vs. Net Income vs. Taxable Income
d) Sources of Income Subject to Tax
(1) Compensation Income
(2) Fringe Benefits
(3) Professional Income
(4) Income from Business
(5) Income from Dealings in Property
(6) Passive Investment Income
(7) Annuities, Proceeds from Life Insurance or Other Types of
Insurance
(8) Prizes and Awards
(9) Pensions, Retirement Benefit or Separation Pay
(10) Income from Any Source
e) Exclusions
(1) Taxpayers Who May Avail
(2) Distinguished from Deductions and Tax Credits
4. Deductions from Gross Income
a) Concept as Return of Capital
b) Itemized Deductions vs. Optional Standard Deduction
c) Items Not Deductible
5. Income Tax on Individuals
a) Resident Citizens, Non-Resident Citizens, and Resident Aliens

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 (1) Inclusions and Exclusions for Taxation on Compensation
Income
(2) Taxation of Business Income/Income from Practice of
Profession
(3) Taxation of Passive Income
(4) Taxation of Capital Gains
(5) Capital Asset vs. Ordinary Asset
b) Income Tax on Non-Resident Aliens Engaged in Trade or Business
c) Income Tax on Non-Resident Aliens Not Engaged in Trade or
Business
d) Individual Taxpayers Exempt from Income Tax
(1) Senior Citizens
(2) Minimum Wage Earners
(3) Exemptions Granted Under International Agreements
6. Income Tax on Corporations
a) Income Tax on Domestic Corporations and Resident Foreign
Corporations
(1) Branch Profit Remittance Tax
(2) Itemized Deductions vs. Optional Standard Deductions
b) Income Tax on Non-Resident Foreign Corporations
c) Income Tax on Special Corporations
d) Exemptions from Tax on Corporations
e) Period Within Which to File Income Tax Return of Individuals and
Corporations
f) Substituted Filing g) Failure to File Returns
7. Withholding Taxes
a) Concept
b) Creditable vs. Withholding Taxes
C. Value-Added Tax (VAT)
1. Concept and Elements of VATable Transactions
2. Impact and Incidence of Tax
3. Destination Principle and Cross-Border Doctrine
4. Imposition of VAT on Transfer of Goods by Tax Exempt Persons
5. Transactions Deemed Sale Subject to VAT
6. Zero-Rated and Effectively Zero-Rated Sales of Goods or Properties
7. VAT-Exempt Transactions
8. Input and Output Tax
9. Tax Refund or Tax Credit
10. Filing of Returns and Payment
D. Tax Remedies Under the National Internal Revenue
1. Assessment of Internal Revenue Taxes
a) Procedural Due Process in Tax Assessments
b) Requisites of a Valid Assessment
c) Tax Delinquency vs. Tax Deficiency
d) Prescriptive Period for Assessment
(1) False Returns vs. Fraudulent Returns vs. Non-Filing of Returns
(2) Suspension of the Running of Statute of Limitations

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 2. Taxpayer’s Remedies
a) Protesting an Assessment
(1) Period to File Protest
(2) Submission of Supporting Documents
(3) Effect of Failure to File Protest
(4) Action of the Commissioner on the Protest Filed
b) Compromise and Abatement of Taxes
c) Recovery of Tax Erroneously or Illegally Collected
3. Government Remedies for Collection of Delinquent Taxes
a) Requisites
b) Prescriptive Periods
4. Civil Penalties
a) Delinquency Interest and Deficiency Interest
b) Surcharge
c) Compromise Penalty

III. Local Taxation

A. Local Government Taxation
1. General Principles
2. Nature and Source of Taxing Power
a) Grant of Local Taxing Power Under the Local Government Code
b) Authority to Prescribe Penalties for Tax Violations
c) Authority to Grant Local Tax Exemptions
d) Withdrawal of Exemptions
3. Scope of Taxing Power
4. Specific Taxing Power of Local Government Units
5. Common Revenue Raising Powers
6. Community Tax
7. Common Limitations on the Taxing Powers of Local Government Units
8. Requirements for a Valid Tax Ordinance
9. Taxpayer's Remedies
a) Protest
b) Refund
c) Action before the Secretary of Justice
10. Assessment and Collection of Local Taxes
a) Remedies of Local Government Units
b) Prescriptive Period
B. Real Property Taxation
1. Fundamental Principles
2. Nature
3. Imposition
a) Power to Levy
b) Exemption from Real Property Tax
4. Appraisal and Assessment
a) Classes of Real Property
b) Assessment Based on Actual Use
5. Collection

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 a) Date of Accrual
b) Periods to Collect
c) Remedies of Local Government Units
6. Taxpayer’s Remedies
a) Contesting an Assessment
(1) Payment Under Protest; Exceptions
b) Contesting a Valuation of Property
(1) Appeal to the Local Board of Assessment Appeals
(2) Appeal to the Central Board of Assessment Appeals
(3) Effect of Payment of Taxes
c) Compromise of Real Property Tax Assessment

IV. Judicial Remedies

A. Court of Tax Appeals (CTA)
1. Exclusive Original and Appellate Jurisdiction Over Civil Cases
2. Exclusive Original and Appellate Jurisdiction Over Criminal Cases
B. Procedures
1. Filing of an Action for Collection of Taxes
a) Internal Revenue Taxes
b) Local Taxes
2. Civil Cases
a) Who May Appeal, Mode of Appeal, and Effect of Appeal
b) Suspension of Collection of Taxes
c) Injunction Not Available to Restrain Collection
3. Criminal Cases
a) Institution and Prosecution of Criminal Action
b) Institution of Civil Action in Criminal Action
c) Period to Appeal
4. Appeal to the CTA En Banc
5. Petition for Review on Certiorari to the SC
----------------------------------------NOTHING FOLLOWS—--------------------------------------

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