Legal Insights
Plain-language guides and case briefs on Philippine law — researched from the firm's law library of 184,000+ statutes, Supreme Court decisions, and agency issuances, and written so non-lawyers can understand and act on them.
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Res Judicata and Due Process in Tax Sales: When a Prior Case Does Not Bar a New Suit
The Supreme Court clarifies when res judicata applies in tax delinquency sales and protects property owners' right to due process.
Res Judicata and Due Process in Tax Sales: Ignacio v. City Treasurer of Quezon City
When a tax sale is challenged for lack of notice, res judicata may not bar the case if the earlier judgment did not rule on the sale's validity.
Withholding Tax Obligations: When Final Withholding Tax Becomes Due
Learn when final withholding tax obligations arise under Philippine tax law, based on a Supreme Court ruling on interest payments.
VAT Refund Claims: Why the 120-Day Rule Is Jurisdictional and Deadlines Matter
Learn how the Supreme Court's ruling in Aichi Forging clarifies the mandatory 120-day VAT refund waiting period and its impact on taxpayers.
Taxing Power vs National Electrification: LGU Levy on Electric Cooperatives
Supreme Court rules LGUs may levy electric cooperative properties for unpaid real property taxes despite EPIRA restrictions.
PD 242 and Intra-Government Tax Disputes: Who Decides When BIR Faces Another Agency?
Supreme Court clarifies that PD 242 governs disputes solely between government entities, giving the DOJ Secretary jurisdiction over BIR-PSALM VAT cases.
Tax Sale Deposit Rule: When Section 267 of the Local Government Code Does Not Apply
Supreme Court clarifies when the Section 267 deposit requirement for tax sale challenges does not apply, remanding Beaumont case for trial.
Tax Assessment Waivers Must Strictly Comply With BIR Rules or Prescription Applies
Learn how defective tax waivers fail to extend the BIR's three-year assessment period, from the Supreme Court's ruling in CIR v. Systems Technology Institute.
Expropriation and Capital Gains Tax: Who Pays When Government Takes Property?
Supreme Court rules property owners, not the government, pay capital gains tax in expropriation cases. Learn the tax implications.
Tax Assumption vs. Tax Exemption: Who Pays When International Agreements Are Involved
The Supreme Court clarifies the difference between tax assumption and tax exemption in Mitsubishi Corporation v. CIR, and who bears the tax burden.
Tax Assumption vs. Tax Exemption: The Mitsubishi Ruling on Government-Promised Tax Relief
The Supreme Court clarifies when a government's promise to assume taxes binds the state—and when it doesn't—in this landmark Philippine tax case.
Equitable Estoppel and Tax Refund Claims: The Exception to the 120+30-Day Rule
Explains the Supreme Court's ruling in Visayas Geothermal Power Co. v. CIR, applying equitable estoppel to the 120+30-day tax refund rule.
Contempt of Court for Defying a Corporate Rehabilitation Order in the Philippines
The Supreme Court affirms contempt charges against BIR officials who pursued deficiency tax claims despite a corporate rehabilitation Commencement Order.
Excise Tax on Cigarette Bundles: The Sin Tax Law and Packaging Rules
The Supreme Court ruled that excise tax applies to a 20-stick bundle as a whole, not to individual 5s or 10s pouches.
HMO VAT Assessments Void Without Letter of Authority: Medicard Case
Supreme Court voids HMO VAT assessment without Letter of Authority; only service fees, not earmarked medical funds, are taxable gross receipts.
When BIR Assessments Become Final: Why Taxpayers Must Act on Unchallenged Notices
Understand why unchallenged BIR assessments become final and executory, and what taxpayers must do to protect their rights.
Franchise Tax After EPIRA: NPC's Liability and the Limits of Local Government Power
The Supreme Court clarifies when the local franchise tax applies after EPIRA, nullifying Bataan's levy on NPC properties.
Reconveyance and Land Ownership: Proving Ownership in Land Disputes
The Supreme Court nullified a provincial government's levy and auction of NPC properties, clarifying franchise tax rules under EPIRA.
Local Franchise Tax After EPIRA: When Government Levy on Power Assets Fails
The Supreme Court nullified Bataan's levy on Napocor assets, clarifying local franchise tax limits after EPIRA's transfer of power functions.
Submarine Cables as Taxable Real Property: Supreme Court Clarifies Local Government Authority
The Supreme Court rules submarine cables are taxable real property, affirming local governments' power to impose real property tax on these assets.
Tax Assessment Falsity of Returns and the Ten-Year Prescriptive Period
When do false returns trigger the 10-year tax assessment period? The Supreme Court clarifies the rules on prescription and notice.
PAL Franchise Tax Exemption Survives Later Tax Laws: Supreme Court Ruling
The Supreme Court affirms PAL's excise tax exemption under PD 1590 despite RA 9334 and RA 9337 amendments.
Tax on Non-Profit Hospitals: Balancing Charity and Commerce in Philippine Law
Philippine Supreme Court clarifies that non-profit hospitals like St. Luke's pay 10% tax on income from paying patients, balancing charity and commerce.
When a Non-Profit Hospital Still Pays Income Tax: The St. Luke's Ruling
The Supreme Court explains when a charitable hospital's income from paying patients becomes taxable under the NIRC.