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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When Tax Disputes Between Government Agencies Must Be Settled Administratively
Supreme Court ruling on whether tax disputes between government agencies go to the CTA or administrative settlement under P.D. 242.
Executive Authority vs Judicial Review: Resolving Tax Disputes Between Government Entities
The Supreme Court rules that tax disputes between executive agencies must first undergo administrative settlement, not judicial review.
Rehabilitation Courts and Tax Disputes: The Power to Resolve Claims Tied to the Rehabilitation Plan
The Supreme Court clarifies when a rehabilitation court may resolve claims involving local tax disputes, distinguishing incidental claims from those requiring separate actions.
Navigating Creditable Withholding Tax Disputes in Construction Contracts: Insights from a Landmark Supreme Cou
A Supreme Court ruling clarifies when withholding agents may deduct creditable withholding tax and the limits of judicial review of CIAC arbitral awards.
Understanding the Timely Filing of Appeals: A Crucial Lesson From Philippine Land Disputes
The Supreme Court clarifies the 30-day appeal period in tax disputes, using a land dispute analogy to explain finality and jurisdiction.
Navigating Tax Assessments: The Importance of Timely Appeals in the Philippines
Learn why timing matters in Philippine tax disputes and how missing an appeal deadline can forfeit a taxpayer's right to challenge an assessment.
Navigating Tax Law Conflicts: Understanding the Jurisdictional Limits of Courts in Tax Disputes
The Supreme Court clarifies the boundaries of judicial review in tax cases, emphasizing that courts cannot substitute their judgment for that of tax authorities.
When Technicalities Yield to Justice: Procedural Lapses in Tax Appeals
The Supreme Court reminds the CTA that procedural rules must serve justice, not defeat it, in tax disputes.
Real Property Tax Disputes: Location, Titles, and Escrow When LGUs Compete
When two LGUs claim the same property for real estate tax, who gets paid? The Supreme Court's answer in Municipality of Cainta v. Spouses Braña.
Government Agencies and Surety Bonds in Real Property Tax Disputes: The PMO v. CTA Ruling
When can a government agency skip the surety bond in real property tax cases? The Supreme Court clarifies in PMO v. CTA.
Certiorari Denied: Exhausting Appeals Before Seeking Extraordinary Writs in Tax Disputes
Learn why the Supreme Court denied certiorari in a forfeiture case, emphasizing the need to exhaust appeals before seeking extraordinary writs.
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.
Real Property Tax Disputes: Why Payment Under Protest Is a Mandatory First Step
Philippine Supreme Court clarifies that payment under protest is mandatory before appealing real property tax assessments, even when claiming tax exemption.
Exhaustion of Administrative Remedies and CTA Jurisdiction in Tax Disputes
The Supreme Court clarifies that the CTA cannot review the CIR's quasi-legislative interpretation of tax laws, and taxpayers must exhaust administrative remedies first.
When Can RTCs Rule on the Constitutionality of Administrative Regulations?
The Supreme Court clarifies the limits of judicial review, the proper venue for tax disputes, and the tax exemption of the PEZA.
Compromise Agreements Prevail Resolving Tax Disputes Through Mutual Concessions
When parties settle tax disputes by compromise, courts may set aside prior rulings. The Supreme Court explains the binding effect of such agreements.
Tax Refund vs Tax Credit: Execution Requirements in Local Tax Disputes
Philippine Supreme Court clarifies when a writ of execution is needed for tax refunds or tax credits in local tax disputes.
CTA Jurisdiction Over Local Tax Disputes: The City of Manila v. Grecia-Cuerdo Ruling
The Supreme Court clarifies that the Court of Tax Appeals has jurisdiction over certiorari petitions questioning RTC interlocutory orders in local tax cases.
Tax Exemption vs Assessment: Understanding Payment Under Protest in Real Property Tax Disputes
Philippine Supreme Court clarifies that claiming tax exemption does not excuse payment under protest before appealing a real property tax assessment.
Navigating Tax Disputes: The Proper Legal Remedy for Assessment Protests in the Philippines
Learn the correct legal remedy when protesting a local business tax assessment, based on a Supreme Court ruling on the Local Government Code.
When Can Government Agencies Be Sued? The ATO Case on Tax and Sovereign Immunity
Explaining when Philippine government agencies can be sued, using the Air Transportation Office case on property tax disputes.
Land Ownership Disputes: Proving Your Claim in the Philippines
Learn how the Supreme Court distinguishes government instrumentalities from GOCCs in real property tax disputes, and what this means for proving ownership claims.
Finality of Tax Assessments: Why Collection Efforts Don't Reopen Tax Disputes
When do collection letters and lawsuits reopen settled tax assessments? The Supreme Court clarifies in Pilipinas Shell v. Commissioner of Customs.
Missed Deadlines Lost Refunds: The Importance of Timely Filing in Tax Disputes
A Supreme Court ruling underscores that missed deadlines and counsel's negligence can bar tax refund claims, emphasizing the finality of judgments.