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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Due Process in Tax Assessments: When BIR Service of Notices Fails
Supreme Court voids BIR deficiency assessments served on unauthorized persons, stressing strict due process rules in tax collection.
Tax Collection Prescription: CIR's Collection Efforts Barred by Three-Year Period
Supreme Court affirms CTA ruling that the CIR's right to collect deficiency taxes prescribed after three years from assessment notice.
Navigating Tax Assessments: Understanding the Limits of Declaratory Relief in Philippine Tax Law
The Supreme Court clarifies when declaratory relief cannot be used to challenge tax assessments, reinforcing the rule against enjoining tax collection.
Understanding the Limits of Garnishment in Tax Collection: Insights From the Philippine Supreme Court
The Supreme Court clarifies that impeachment only removes an official from office, not forfeits retirement benefits without judicial conviction.
Tax Injunctions and Declaratory Relief: Limits on Court Authority
The Supreme Court clarifies that courts cannot enjoin tax collection and that declaratory relief is not a proper remedy to contest tax assessments.
Tax Credit Transfers: Protecting Transferees in Good Faith and Upholding Due Process
The Supreme Court shields innocent transferees of tax credit certificates from reassessment, affirming due process in tax collection.
State's Right to Recover Public Funds: Prescription Does Not Run Against the Government
Supreme Court rules the government's right to recover illegally disbursed public funds does not prescribe, but limits COA's power over tax collection.
Prescription and COA Authority Over Disbursed Public Funds: Ramiscal v. COA
The Supreme Court clarifies that the State's right to recover illegally disbursed public funds does not prescribe, but limits COA's power over tax collection.
Taxation and Due Process: Balancing Government Power and Taxpayer Rights in Deficiency Assessments
The Supreme Court clarifies when the CTA may require a surety bond to suspend tax collection, protecting taxpayer rights.
Tax Suspension Bonds: When the CTA Must Hear the Taxpayer First
The Supreme Court clarifies when the Court of Tax Appeals may require a bond to suspend tax collection, and why a preliminary hearing is essential.
Navigating Appeals Jurisdiction of the Court of Tax Appeals in Collection Cases
A Supreme Court ruling clarifies that the CTA has exclusive appellate jurisdiction over tax collection cases, and wrong appeals must be dismissed.
Tax Collection: Government's Right to Collect Taxes Limited by Prescription
Supreme Court rules BIR's right to collect assessed taxes prescribes in three years; inaction bars collection.
Prescription in Tax Collection: The Imperative of Valid Waivers and Timely Action by the BIR
When the BIR fails to act on a protest or secure a valid waiver, its right to collect deficiency taxes prescribes. This case explains the rules.
Prescription in Tax Collection: When Does the Government Lose Its Right to Collect
Philippine Supreme Court ruling on prescription periods for tax collection and when the government's right to collect prescribed taxes expires.
Local Tax Injunctions: Balancing Government Revenue and Taxpayer Rights in the Philippines
Philippine Supreme Court ruling on when courts may enjoin local tax collection, balancing government revenue needs with taxpayer rights.
Customs Bonds: Contractual Obligations vs Tax Collection Cases
Supreme Court clarifies that suits on customs bonds are contractual, not tax collection cases, so appeals go to the Court of Appeals.
Tax Collection vs Right to Appeal: Balancing Government Power and Taxpayer Protection
Philippine Supreme Court ruling on when posting a surety bond can suspend real property tax collection and protect taxpayer rights.
When Can Government Revoke Tax Exemptions in Freeport Zones
Philippine Supreme Court ruling on when Congress may withdraw tax exemptions granted to Subic Freeport locators, and limits on injunctions against tax collection.
Tax Collection Deadlines: Prescription in Philippine Tax Law Explained
Learn how the BPI v. CIR case clarifies the three-year prescription period for tax collection and when it may be suspended.
When BIR Regional Directors Can File Tax Collection Cases: The Hizon Ruling
Philippine Supreme Court clarifies BIR regional directors' authority to file tax collection suits and the prescription rules under the NIRC.
Deficiency Tax Collection: When BIR Warrants Are Premature Under Philippine Law
Philippine Supreme Court clarifies when BIR collection of deficiency taxes is premature, and why the OSG must represent the CIR.
Estate Tax Collection: BIR Authority vs. Probate Court Jurisdiction
Supreme Court ruling on whether the BIR can levy estate properties without probate court approval, and the finality of tax assessments.