CityofBaguiovs.

DeLeon
CITYOFBAGUIOvs.DELEON
25SCRA938
GRNo.L24756,October31,1968
"Thereisnodoubletaxationwhereonetaxisimposedbythestateandthe
otherisimposedbythecity."
FACTS:TheCityofBaguiopassedanordinanceimposingalicensefeeon
anyperson,entityorcorporationdoingbusinessintheCity.Theordinance
sourceditsauthorityfromRANo.329,therebyamendingthecitycharter
empowering it to fix the license fee and regulate businesses, trades and
occupationsasmaybeestablishedorpracticedintheCity.DeLeonwas
assessedforP50annualfeeitbeingshownthathewasengagedinproperty
rentalandderivingincometherefrom.Thelatterassailedthevalidityofthe
ordinancearguingthatitisultraviresforthereisnostaturyauthoritywhich
expressly grants the City of Baguio to levy such tax, and that there it
imposeddoubletaxation,andviolatestherequirementofuniformity.
ISSUE:Arethecontentionsofthedefendantappellanttenable?
HELD: No. First, RA 329 was enacted amending Section 2553 of the
Revised Administrative Code empowering the City Council not only to
imposealicensefeebuttolevyataxfor purposesof revenue,thusthe
ordinance cannot be considered ultra vires for there is more than ample
staturyauthorityfortheenactmentthereof.
Second,anargumentagainstdoubletaxationmaynotbeinvokedwhere
onetaxisimposedbythestateandtheotherisimposedbythecity,sothat
where,ashere,Congresshasclearlyexpresseditsintention,thestatutemust
besustainedeventhoughdoubletaxationresults.
Andthird,violationofuniformityisoutofplaceitbeingwidely
recognizedthatthereisnothinginherentlyobnoxiousintherequirementthat
licensefeesortaxesbeexactedwithrespecttothesameoccupation,calling
oractivitybyboththestateandthepoliticalsubdivisionsthereof.

Sison vs Ancheta (1984)

Facts: Batas Pambansa 135 was enacted. Sison, as
taxpayer, alleged that its provision (Section 1)
unduly discriminated against him by the
imposition of higher rates upon his income as a
professional, that it amounts to class legislation,
and that it transgresses against the equal
protection and due process clauses of the
Constitution as well as the rule requiring
uniformity in taxation.
Issue: Whether BP 135 violates the due process
and equal protection clauses, and the rule on
uniformity in taxation.
Held: There is a need for proof of such persuasive
character as would lead to a conclusion that there
was a violation of the due process and equal
protection clauses. Absent such showing, the
presumption of validity must prevail. Equality and
uniformity in taxation means that all taxable
articles or kinds of property of the same class shall
be taxed at the same rate. The taxing power has the
authority to make reasonable and natural
classifications for purposes of taxation. Where the
differentitation conforms to the practical dictates
of justice and equity, similar to the standards of

equal protection, it is not discriminatory within the

meaning of the clause and is therefore uniform.
Taxpayers may be classified into different
categories, such as recipients of compensation
income as against professionals. Recipients of
compensation income are not entitled to make
deductions for income tax purposes as there is no
practically no overhead expense, while
professionals and businessmen have no uniform
costs or expenses necessaryh to produce their
income. There is ample justification to adopt the
gross system of income taxation to compensation
income, while continuing the system of net income
taxation as regards professional and business
income.

Ormoc Sugar Company, Inc. v.

Treasurer of Ormoc City [G.R.
No. 23794 February 17, 1968]
Facts: The Municipal Board of Ormoc City passed
Ordinance No. 4 imposing on any and all
productions of centrifugal sugar milled at the
Ormoc Sugar Company, Inc., in Ormoc City a
municipal tax equivalent to one per centum (1%)
per export sale to USA and other foreign
countries. Payments for said tax were made, under
protest, by Ormoc Sugar Company, Inc. Ormoc

Sugar Company, Inc. filed before the Court of First

Instance of Leyte a complaint against the City of
Ormoc as well as its Treasurer, Municipal Board
and Mayor alleging that the ordinance is
unconstitutional for being violative of the equal
protection clause and the rule of uniformity of
taxation. The court rendered a decision that upheld
the constitutionality of the ordinance. Hence, this
appeal.

Issue: Whether or not constitutional limits on the

power of taxation, specifically the equal protection
clause and rule of uniformity of taxation, were
infringed?

Held: Yes. Equal protection clause applies only to

persons or things identically situated and does not
bar a reasonable classification of the subject of
legislation, and a classification is reasonable where
1) it is based upon substantial distinctions; 2) these
are germane to the purpose of the law; 3) the
classification applies not only to present
conditions, but also to future conditions
substantially identical to those present; and 4) the
classification applies only to those who belong to
the same class. A perusal of the requisites shows

that the questioned ordinance does not meet them,

for it taxes only centrifugal sugar produced and
exported by the Ormoc Sugar Company, Inc. and
none other. The taxing ordinance should not be
singular and exclusive as to exclude any
subsequently established sugar central for the
coverage of the tax.

Reyesvs.Almanzor
REYESv.ALMANZOR
GRNos.L4983946,April26,1991
196SCRA322
FACTS:PetitionersJBLReyesetal.ownedaparceloflandinTondowhich
areLEASED andoccupiedasdwelling
unitsbytenantswhowerepayingmonthlyrentalsofnotexceedingP300.
Sometimesin1971theRental
FreezingLawwaspassedprohibitingforoneyearfromitseffectivity,an
increaseinmonthlyrentalsofdwelling
unitswhererentalsdonotexceedthreehundredpesos(P300.00),sothatthe
Reyeseswereprecludedfrom
raisingtherentsandfromejectingthetenants.In1973,respondentCity
AssessorofManilareclassifiedand
reassessed the value of the subject properties based on the schedule of
marketvalues,whichentailedan
increase in the corresponding tax rates prompting petitioners to file a
MemorandumofDisagreementaverring
that the reassessments made were "excessive, unwarranted, inequitable,
confiscatoryandunconstitutional"
consideringthatthetaxesimposeduponthemgreatlyexceededtheannual
incomederivedfromtheir

properties.Theyarguedthattheincomeapproachshouldhavebeenusedin
determiningthelandvaluesinstead
ofthecomparablesalesapproachwhichtheCityAssessoradopted.
ISSUE: Is the approach on tax assessment used by the City Assessor
reasonable?
HELD:No.Thetaxingpowerhastheauthoritytomakeareasonableand
naturalclassificationforpurposesof
taxation but the government's act must not be prompted by a spirit of
hostility,orattheveryleastdiscrimination
thatfindsnosupportinreason.Itsufficesthenthatthelawsoperateequally
anduniformlyonallpersonsunder
similarcircumstancesorthatallpersonsmustbetreatedinthesamemanner,
theconditionsnotbeingdifferent
bothintheprivilegesconferredandtheliabilitiesimposed.
Consequently,itstandstoreasonthatpetitionerswhoareburdenedbythe
governmentbyitsRentalFreezing
Laws(thenR.A.No.6359andP.D.20)undertheprincipleofsocialjustice
shouldnotnowbepenalizedbythe
samegovernmentbytheimpositionofexcessivetaxespetitionerscanill
affordandeventuallyresultinthe
forfeitureoftheirproperties.