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    Republic vs. Ablaza

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    The government appealed a lower court's dismissal of its action to collect income taxes from the defendant for the years 1945-1948. The lower court upheld the defendant's claim that the action to collect the taxes had prescribed under the statute of limitations. On appeal, the Supreme Court affirmed, ruling that the law prescribing a limitation period for collecting taxes is beneficial to both the government and citizens. It obliges tax officers to act promptly and gives citizens security against harassment by tax agents after the limitation period expires. The law should be interpreted liberally to achieve its beneficial purpose of protecting taxpayers.

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    Republic vs. Ablaza

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    rcmj_supremo3193
    904 views1 page
    The government appealed a lower court's dismissal of its action to collect income taxes from the defendant for the years 1945-1948. The lower court upheld the defendant's claim that the action to collect the taxes had prescribed under the statute of limitations. On appeal, the Supreme Court affirmed, ruling that the law prescribing a limitation period for collecting taxes is beneficial to both the government and citizens. It obliges tax officers to act promptly and gives citizens security against harassment by tax agents after the limitation period expires. The law should be interpreted liberally to achieve its beneficial purpose of protecting taxpayers.

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    The government appealed a lower court's dismissal of its action to collect income taxes from the defendant for the years 1945-1948. The lower court upheld the defendant's claim that the action to collect the taxes had prescribed under the statute of limitations. On appeal, the Supreme Court affirmed, ruling that the law prescribing a limitation period for collecting taxes is beneficial to both the government and citizens. It obliges tax officers to act promptly and gives citizens security against harassment by tax agents after the limitation period expires. The law should be interpreted liberally to achieve its beneficial purpose of protecting taxpayers.

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    904 views1 page

    Republic vs. Ablaza

    Uploaded by

    rcmj_supremo3193
    The government appealed a lower court's dismissal of its action to collect income taxes from the defendant for the years 1945-1948. The lower court upheld the defendant's claim that the action to collect the taxes had prescribed under the statute of limitations. On appeal, the Supreme Court affirmed, ruling that the law prescribing a limitation period for collecting taxes is beneficial to both the government and citizens. It obliges tax officers to act promptly and gives citizens security against harassment by tax agents after the limitation period expires. The law should be interpreted liberally to achieve its beneficial purpose of protecting taxpayers.

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    Topic: STATUTES PRESCRIBING PERIOD TO COLLECT TAXES G.R. No. L-14519 REPUBLIC vs. LUIS G. ABLAZA LABRADOR, J.

    : Action: Appeal from a judgment of the Court dismissing an action instituted by the Government to recover income taxes from the defendant-appellee for the years 1945, 1946, 1947 and 1948. Facts: The Collector of Internal Revenue assessed income taxes for the years 1945, 1946, 1947 and 1948 on the income tax returns of defendant-appellee to a total P5,254.70. Respondent requested a reinvestigation of tax liability which was granted by the Collector of Internal Revenue. Final assessment was fixed at P2,066.56. Respondent protested the assessment contending that the income taxes are no longer collectible for the reason that they have already prescribed. As the Collector did not agree to the alleged claim of prescription, action was instituted for the recovery of the amount assessed. The Court of First Instance upheld the contention of Ablaza that the action to collect the said income taxes had prescribed. Thus this appeal. Issue : Whether or not the claim of prescription by the respondent is valid. Held : Judgment of the lower court dismissing the action is affirmed. Ruling : The law prescribing a limitation of actions for the collection of the income tax is beneficial both to the Government and to its citizens; to the Government because tax officers would be obliged to act promptly in the making of assessment, and to citizens because after the lapse of the period of prescription citizens would have a feeling of security against unscrupulous tax agents who will always find an excuse to inspect the books of taxpayers, not to determine the latter's real liability, but to take advantage of every opportunity to molest peaceful, law-abiding citizens. Without such legal defense taxpayers would furthermore be under obligation to always keep their books and keep them open for inspection subject to harassment by unscrupulous tax agents. The law on prescription being a remedial measure should be interpreted liberally in a way conducive to bringing about the beneficial purpose of affording protection to the taxpayers. July 26, 1960

    By: Roselaine M. Jaranilla Statutory Construction Judge Rosales

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