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1 | T a x a t i o n I | 2017 public purpose.

But if by public purpose the petitioner means benefit


to a taxpayer as a return for what he pays, then it is sufficient to
1. Gomez v. Palomar answer that the only benefit to which the taxpayer is constitutionally
entitled is that derived from his enjoyment of the privileges of living in
GR No. L-23645, October 29, 1968 an organized society, established and safeguarded by the devotion of
taxes to public purposes. Any other view would preclude the levying of
Facts: This petition assails the constitutionality of RA 1635 as taxes except as they are used to compensate for the burden on those
amended which provides that to help raise funds for the Philippine who pay them and would involve the abandonment of the most
Tuberculosis Society, no mail matter shall be accepted in the mails fundamental principle of government that it exists primarily to
unless it bears the semi-postal stamps which bears the regular postage provide for the common good.
stamps plus the additional amount of five centavos for the said
purpose. The additional charge of five centavos will constitute a special
fund to be expended by the PTS.
2. PAL v. Edu, Carbonell
GR No. L-41383, August 15, 1988
In September 1963, petitioner Benjamin Gomez mailed a letter at the
post office of San Fernando, Pampanga but since it did not include the Facts: The Philippine Airlines (PAL) is a corporation organized and
special anti-TB stamp, it was returned to Gomez. Petitioner then existing under Philippine laws and is granted a franchise to operate its
brought a declaratory suit in the CFI of Pampanga to test the air transportation business. Under its franchise, PAL is granted tax
constitutionality of the statute contending that it violates the equal exemption, and on the strength of the opinion of the Secretary of
protection clause of the Constitution as well as the rule of uniformity Justice (Op. No. 307, series of 1956), PAL has since 1956, not been
and equality of taxation. The lower court declared the statute and the paying motor vehicle registration fees. In 1971, Commissioner Elevate
orders unconstitutional. issued a regulation requiring all tax exempt entities, to pay motor
vehicle registration fees. PAL paid Php 19,529.75 under protest.
Issue: W/N RA 1635 is unconstitutional for being violative of the
Subsequently, PALs counsel wrote to Commissioner Edu demanding
equal protection clause and for not being levied for a public purpose.
refund of the amount saying that motor vehicle registration fees are in
Ruling: The Court ruled that the five centavo charge levied is in the reality tax payment to which PAL is exempted to pay under its
nature of an excise tax, laid upon the exercise of a privilege, namely the franchise.
privilege of using the mails. The legislature has the inherent power to
Issue: W/N motor vehicle registration fees are considered as taxes.
select the subjects of taxation and to grant exemptions. This power has
aptly been described as of wide range and flexibility. It is also not Ruling: Yes. It is possible for an exaction to be either a tax or a
violative of the equal protection clause that only tuberculous is singled regulation. License fees are charges looked to as a source of revenue as
out for the fund to the exclusion of other diseases. It is never the well as means of regulation as consequence of the exercise of the
requirement of equal protection that all evils of the same genus be States police power. If the purpose is primarily revenue, or if revenue
eradicated or none at all. is at least one of the real and substantial purposes, then the exaction is
properly called a tax.
It is for a public purpose as the eradication of a dreaded disease is a
2 | T a x a t i o n I | 2017 on the property inherited for any unpaid income taxes. By virtue of
such lien, the Government has the right to subject the property in
Originally, vehicle registration fees were intended only for rigidly Pineda's possession, i.e., the P2, 500.00, to satisfy the income tax
purposes in the exercise of the States police powers. Over the years, assessment in the sum of P760.28. After such payment, Pineda will
however, as vehicular traffic exploded in number and motor vehicles have a right of contribution from his co-heirs, to achieve an adjustment
became absolute necessities, Congress found the registration of of the proper share of each heir in the distributable estate.
vehicles a very convenient way of raising much needed revenues.
Hence, presently motor vehicle registration fees are considered as
taxes. 4. Francia v. IAC
GR No. L-67649, June 28, 1988
3. CIR v. Pineda
Facts: Engracio Francia is the registered owner of a residential lot with
GR No. L-22734, September 15, 1967
a two-story house in Pasay City. In 1977, 125 out of the 328 square
meters of the lot was expropriated by the Republic for more than 4,000
Facts: Anastasio Pineda died and was survived by his wife and equivalent to its assessed value. Since 1963 up to 1977, Francia failed
children. The estate was divided and distributed to his heirs, with Atty. to pay real estate taes and hence, his property was sold at public
Manuel Pineda receiving a share of P2,500.00. After the estate auction to satisfy a tax delinquency of P2,400. Private respondent Ho
proceedings were closed, the BIR investigated the estate tax liabilities Fernandez is the highest bidder. When Ho filed a petition for a new
and discovered that tax returns were not filed and hence, issued an Certificate of Title, Francia filed a complaint to annul the auction sale
assessment covering the years 1945 1947. The SC ruled that the right but the CTA and IAC both ruled in favor of Ho.
to assess and collect tax for the years 1945-1946 had already
prescribed but affirmed the assessment and collection for 1947. The Issue: W/N the tax delinquency may be set off from the amount which
case was then remanded back to the CTA where it ruled that Pineda is the government owed to Francia
liable only to the tax in proportion to his share. CIR appealed
Ruling: No. The court has consistently ruled that there can be no off-
contending that Pineda must be liable to the whole tax due from the
setting of taxes against the claims that the taxpayer may have against
estate, and not merely his portion thereof.
the government. A person cannot refuse to pay a tax on the ground
Issue: W/N Manuel Pineda can be held liable of the whole amount of that the government owes him an amount equal to or greater than the
the unpaid income tax. tax being collected. The collection of a tax cannot await the results of a
lawsuit against the government.
Ruling: Yes. Pineda is liable for the assessment as an heir and as a
holder transferee of property belonging to the estate/taxpayer. As an Furthermore, the tax was due to the city government while the
heir, he is individually answerable for the part of the tax proportionate expropriation was effected by the national government. Also, the
to the share he received from the inheritance. His liability, however, amount for the expropriation has long been deposited to the account of
cannot exceed the amount of his share. As a holder of property Francia long before the public auction of his property. He could have
belonging to the estate, Pineda is liable for the tax up to the amount of easily withdrawn the amount needed so that he could pay the tax
the property in his possession. Sec. 315 of the Tax Code creates a lien obligation thus aborting the sale at public auction.
3 | T a x a t i o n I | 2017 BIR denied the request of Philex stating that the pending claim of the
latter is yet to be determined and established with certainty. Due to
5. Domingo v. Garlitos this, Philex raised the issue with CTA which reduced the obligation but
GR No. L-18994, June 29, 1963 still ordered Philex to pay. While the case was pending before the SC,
its VAT input/refund was credited such that it now contends before
the SC that the BIR should, ipso jure, off-set its excise tax liabilities
Facts: On January 30, 1960, the Supreme Court declared as final and
since both had already become due and demandable, as well as fully
executory the order for the payment by the estate of Walter Scott Price
liquidated.
of the estate and inheritance taxes, charges and penalties amounting to
P40k in the case of Domingo v. Moscoso. In order to enforce the claims Issue: W/N the excise tax liabilities and the VAT input credit/refund
against the estate, the fiscal presented a petition for the execution of may be set-off on compensation.
the judgment. The CFI of Leyte however denied the petition as
execution is not justifiable as the Government is indebted to the estate Ruling: No. It is already settled that taxes cannot be subject to
in the amount of P262,200. The CFI of Leyte however ordered that the compensation for the simple reason that the government and the
amount of taxes be taken from the P262k that the Government still taxpayer are not creditors and debtors of each other. There is a
owes from the estate. material distinction between a tax and a debt. Debts are due to the
Government in its corporate capacity, while taxes are due to the
Issue: W/N set off may take place. Government in its sovereign capacity.

Ruling: Yes. The Court which has jurisdiction over the estate has found
that the claim of the estate against the Government has been 7. Caltex Phil v. COA
recognized and an amount of P262,200 has already been appropriated GR No. 925585, May 8, 1992
for the purpose by a correspondent law. Under the above
circumstances, both the claim of the Government for inheritance taxes
Facts: In 1989, COA sent a letter to Caltex directing it to remit to OPSF
and the claim of the intestate for services rendered have already
its collection of the additional tax on petroleum authorized under PD
become due and demandable as well as fully liquidated. Compensation,
1956 and pending such remittance, all of its claims from the OPSF shall
therefore, takes place by operation of law.
be held in abeyance. Petitioner requested COA for the early release of
its reimbursement certificates from the OPSF covering claims with the
6. Philex Mining Corp v. CIR Office of Energy Affairs. COA denied the same.
GR No. 125704, August 28, 1988 Issue: W/N petitioner can avail of the right to offset any amount that it
may be required under the law to remit to the OPSF against any
Facts: BIR sent a letter to Philex asking it to settle its excise tax amount that it may receive by way of reimbursement.
liabilities in the amount of P 123, 821, 982.52. In its written reply,
Philex protested and stated that it has pending claims for VAT input Ruling: It is a settled rule that a taxpayer may not offset taxes due
credit/refund for the taxes it paid in the amount of P 119, 977 plus from the claims that he may have against the government. Taxes
interest, thus claiming set-off between its tax liabilities and tax claims. cannot be the subject of compensation because the government and
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9. PAL v. Edu, Carbonell
taxpayer are not mutually debtors and creditors of each other and a GR No. L-41383, August 15, 1988
claim for taxes is not such a debt, demand, contract or judgment as is See no. 2, page 1.
allowed to be set-off. The oil companies merely acted as agents for the
government in the latters collection since taxes are passed unto the
end-users, the consuming public. 10. Lutz v. Araneta
95 Phil 148

8. Vera v. Fernandez Facts: In 1940, Commonwealth Act No. 567, otherwise known as the
GR No. L-31364, March 30, 1979 Sugar Adjustment Act was promulgated. The law wanted to obtain a
readjustment of benefits derived from the sugar industry and to
Facts: The BIR sought to claim the payment of taxes representing the stabilize the sugar industry.
estate's tax deficiencies intestate proceedings of Luis Tongoy. The
Walter Lutz, seeks to recover from the Collector of Internal Revenue
administrator opposed arguing that the claim was already barred by
the sum of P14,666.40 paid by the estate as taxes, under section 3 of
the statute of limitation for under the RoC, all claims for money against
the Act. He alleged that such tax is unconstitutional and void, being
the decedent, arising from contracts, express or implied, whether the
levied for the aid and support of the sugar industry exclusively, which
same be due, not due, or contingent, all claims for funeral expenses and
in plaintiff's opinion is not a public purpose for which a tax may be
expenses for the last sickness of the decedent, and judgment for money
constitutionally levied. His action was dismissed by the CFI and was
against the decedent, must be filed within the time limited in the
appealed directly to the SC.
notice; otherwise they are barred forever.
Issue: W/N the taxes imposed by Commonwealth Act No. 567,
Issue: Does the rule bar recovery by the Government of unpaid taxes?
otherwise known as the Sugar Adjustment Act are legal.
Ruling: No. The reason for the more liberal treatment of claims for
Ruling: Yes. The Supreme Court held that the analysis of the Act, and
taxes against a decedent's estate in the form of exception from the
particularly of section 6 will show that the tax is levied with a
application of the statute of non-claims, is not hard to find. Taxes are
regulatory purpose, to provide means for the rehabilitation and
the lifeblood of the Government and their prompt and certain
stabilization of the threatened sugar industry. In other words, the act is
availability are imperious need. To safeguard such interest, neglect or
primarily an exercise of the police power.
omission of government officials entrusted with the collection of taxes
should not be allowed to bring harm or detriment to the people, in the Sugar production is one of the great industries of our nation and that
same manner as private persons may be made to suffer individually on it is a great source of the state's wealth. The protection of a large
account of his own negligence, the presumption being that they take industry constituting one of the great sources of the state's wealth and
good care of their personal affairs. This should not hold true to therefore directly or indirectly affecting the welfare of so great a
government officials with respect to matters not of their own personal portion of the population of the State is affected to such an extent by
concern. This is the philosophy behind the government's exception, as public interests as to be within the police power of the sovereign. The
a general rule, from the operation of the principle of estoppel.
5 | T a x a t i o n I | 2017 was approved by the President. Inasmuch as the land on which the
projected feeder roads were to be constructed belonged then to
protection and promotion of the sugar industry is a matter of public respondent Zulueta, the result is that said appropriation sought a
concern, it follows that the Legislature may determine within private purpose, and hence, was null and void.
reasonable bounds what is necessary for its protection. Taxation may
be made the implement of the state's police power.

Even from the standpoint that the Act is a pure tax measure, it cannot 12. Pepsi-Cola v. Butuan City
be said that it constitutes expenditure of tax money for private 24 SCRA 789
purposes.

11. Pascual v. Sec of Public Works


GR No. No. L-10405, December 29,
1960

Facts: Republic Act No. 920 was approved on June 20, 1953. It was act
that would appropriate funds for the construction of Pasig feeder road
terminals. Pascual instituted this action upon the ground that said
appropriation was made by Congress because its members were made
to believe that the projected feeder roads in question were "public
roads and not private streets of a private subdivision". Pascual alleges
that when the appropriation was approved the roads in question were
private property owned by Senator Zulueta and that on Dec 12, 1953
Senator Zulueta donated parcels of land to the government in order to
give a semblance of legality to the appropriation.

Issue: W/N the appropriation was valid and was for public purpose

Ruling: NO. The validity of a statute depends upon the powers of


Congress at the time of its passage or approval, not upon events
occurring, or acts performed, subsequently thereto, unless the latter
consists of an amendment of the organic law, removing, with
retrospective operation, the constitutional limitation infringed by said
statute. The legality of the appropriation depended upon whether said
roads were public or private property when the bill, which, later on,
became Republic Act 920, was passed by Congress, or, when said bill
6 | T a x a t i o n I | 2017 Also, there is no validity to the assertion that the delegated authority
can be declared unconstitutional on the theory of double taxation. It
13. Pepsi-Cola v. Municipality of Tanauan must be observed that the delegating authority specifies the
GR No. L-31156, February 27, 1976 limitations and enumerates the taxes over which local taxation may
not be exercised. The reason is that the State has exclusively reserved
the same for its own prerogative. Moreover, double taxation, in
Facts: Plaintiff-appellant Pepsi-Cola commenced a complaint with general, is not forbidden by our fundamental law, so that double
preliminary injunction to declare Section 2 of Republic Act No. 2264, taxation becomes obnoxious only where the taxpayer is taxed twice for
otherwise known as the Local Autonomy Act, unconstitutional as an the benefit of the same governmental entity or by the same jurisdiction
undue delegation of taxing authority as well as to declare Ordinances for the same purpose, but not in a case where one tax is imposed by
Nos. 23 and 27 denominated as "municipal production tax" of the the State and the other by the city or municipality.
Municipality of Tanauan, Leyte, null and void. Ordinance 23 levies and
collects from soft drinks producers and manufacturers a tax of one- On the last issue raised, the ordinances do not partake of the nature of
sixteenth (1/16) of a centavo for every bottle of soft drink corked, and a percentage tax on sales, or other taxes in any form based thereon.
Ordinance 27 levies and collects on soft drinks produced or The tax is levied on the produce (whether sold or not) and not on the
manufactured within the territorial jurisdiction of this municipality a sales. The volume capacity of the taxpayer's production of soft drinks
tax of ONE CENTAVO (P0.01) on each gallon (128 fluid ounces, U.S.) of is considered solely for purposes of determining the tax rate on the
volume capacity. Aside from the undue delegation of authority, products, but there is not set ratio between the volume of sales and the
appellant contends that it allows double taxation, and that the subject amount of the tax.
ordinances are void for they impose percentage or specific tax.

Issue: W/N the contentions of the appellant tenable?

Ruling: No. On the issue of undue delegation of taxing power, it is


settled that the power of taxation is an essential and inherent attribute
of sovereignty, belonging as a matter of right to every independent
government, without being expressly conferred by the people. It is a
power that is purely legislative and which the central legislative body
cannot delegate either to the executive or judicial department of the
government without infringing upon the theory of separation of
powers. The exception, however, lies in the case of municipal
corporations, to which, said theory does not apply. Legislative powers
may be delegated to local governments in respect of matters of local
concern. By necessary implication, the legislative power to create
political corporations for purposes of local self-government carries
with it the power to confer on such local governmental agencies the
power to tax.
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15. Bagatsing v. Ramirez
74 S 306
14. Abakada Guro v. Ermita
Facts: In 1974, the Municipal Board of Manila enacted Ordinance 7522,
regulating the operation of public markets and prescribing fees for the
rentals of stalls and providing penalties for violation thereof. The
Federation of Manila Market Vendors Inc. assailed the validity of the
ordinance, alleging among others the non-compliance to the
publication requirement under the Revised Charter of the City of
Manila.

Issue: WN the publication requirement was complied with.

Ruling: The Revised Charter of the City of Manila is a special act since
it relates only to the City of Manila, whereas the Local Tax Code id a
general law because it applies universally to all local governments.
Section 17 of the Charter speaks of ordinance in general. Whereas,
Section 43 of the Local Tax Code relates to ordinances levying or
imposing taxes, fees or other charges in particular. While the Charter
requires publication, before the enactment of the ordinance and after
approval thereof, in two daily newspapers of the general circulation in
the city, the Local Tax Code only prescribes for publication widely
circulated within the jurisdiction of the local government or by posting
the ordinance in the local legislative hall or premises and in two other
conspicuous places within the territorial jurisdiction of the local
government. Being a general law with a special provision applicable in
the case, the Local Tax Code prevails.
8 | T a x a t i o n I | 2017 17.
16. National Development Co. (NDC) v.
Commissioner Mactan Cebu International Airport v. Marcos GR No. 120082, September
GR No. L-53961, June 1987 11, 1996

Facts: Since the time of its creation, petitioner MCIAA enjoyed the
Facts: The National Development Co. (NDC) entered into contracts in
privilege of exemption from payment of realty taxes in accordance with
Tokyo with several Japanese shipbuilding companies for the
Section 14 of its charter. However, on October 11, 1994, Mr. Eustaquio B.
construction of 12 ocean-going vessels. Initial payments were made in
Cesa, Officer in Charge, Office of the Treasurer of the City of Cebu,
cash and through irrevocable letters of credit. When the vessels were
demanded payment from realty taxes in the total amount of
completed and delivered to the NDC in Tokyo, the latter remitted to
P2229078.79. Petitioner objected to such demand for payment as
the shipbuilders the amount of US$ 4,066,580.70 as interest on the
baseless and unjustified claiming in its favor the aforecited Section 14 of
balance of the purchase price. No tax was withheld. The Commissioner
then held NDC liable on such tax in the total amount of P5,115,234.74. R.A. 6958. It was also asserted that it is an instrumentality of the
The Bureau of Internal Revenue served upon the NDC a warrant of government performing governmental functions, citing Section 133 of the
distraint and levy after negotiations failed. Local Government Code of 1991. Respondent City refused to cancel and
set aside petitioners realty tax account, insisting that the MCIAA is a
Issue: W/N the NDC is liable for deficiency tax. government-controlled corporation whose tax exemption privilege has
been withdrawn by virtue of Sections 193 and 234 of Labor Code that took
Ruling: The Japanese shipbuilders were liable on the interest remitted
effect on January 1, 1992. Issue: W/N the petitioner is a taxable person
to them under Section 37 of the Tax Code. The NDC is not the one
Rulings: Taxation is the rule and exemption is the exception. MCIAAs
taxed. The imposition of the deficiency taxes on the NDS is a penalty
for its failure to withhold the same from the Japanese shipbuilders. exemption from payment of taxes is withdrawn by virtue of Sections 193
Such liability is imposed by Section 53(c) of the Tax Code. NDC was and 234 of Labor Code. Statutes granting tax exemptions shall be strictly
remiss in the discharge of its obligation of its obligation as the construed against the taxpayer and liberally construed in favor of the
withholding agent of the government and so should be liable for its taxing authority. The petitioner cannot claim that it was never a taxable
omission. person under its Charter. It was only exempted from the payment of
realty taxes. The grant of the privilege only in respect of this tax is
conclusive proof of the legislative intent to make it a taxable person
subject to all taxes, except real property tax.

American Bible v. City of Manila GR No. L-9637, April 30, 1957

Facts: American Bible Society's Philippine agency has been distributing


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and selling bibles and/or gospel portions thereof (since 1898, but except 1189 is valid. Ruling: The deed constituted a contract between the Spanish
during the Japanese occupation) throughout the Philippines and government & Casanovas. The obligation in the contract was impaired by
translating the same into several Philippine dialects. According to the City the enactment of Sec. 134 of the Internal Revenue Code, thereby
Treasurer however, the Society is performing a business of general infringing on the provisions of Sec. 5 of the Act of Congress of July 1, 1902,
merchandise without having the necessary Mayors permit and license in which indicate that concessions can be cancelled only by reason of
violation of an municipal ordinances. The Society paid the fees in protest illegality in the procedure by which thy were obtained, or for failure to
and then questioned the validity of the municipal ordinances. Issue: W/N comply with the conditions prescribed as regards requisites for their
the Society is required to secure municipal permit to allow it to distribute retention in the laws under which they are granted.
bibles and religious literature and to pay tax sales from the sales thereof.
Ruling: No, Section 27(e) of CA 466 (NIRC) exempts corporations or CEPALCO v. CIR GR No. L-60126, September 25, 1986
associations organized and operated exclusively for religious, charitable, Facts: Cagayan Electric is a holder of a legislative franchise under RA 3247
or educational purposes, except that they may be taxed for any activity where payment of 3% tax on gross earning is in lieu of all taxes and
conducted for profit. The act of distributing and selling bibles, etc. is assessments upon privileges. In 1968, RA 5431 amended the franchise by
purely religious and cannot be made liable for taxes or fees therein. making all corporate taxpayers liable for income tax. In 1969, through RA
Further, Ordinance 2529, as amended, cannot be applied to the Society, 6020, its franchise was extended to two other towns and the tax
for in doing so it would impair its free exercise and enjoyment of its exemption was reenacted. The commissioner required the company to
religious profession and worship as well as its rights of dissemination of pay deficiency income taxes for the intervening period (1968-1969). Issue:
religious beliefs. The fact that the price of the bibles and other religious Is CEPALCO liable for the tax?
pamphlets are little higher than the actual cost of the same does not
necessarily mean that it is already engaged in the business or occupation Ruling: Yes. Congress could impair the companys legislative franchise by
of selling said merchandise for profit. making it liable for income tax. The Constitution provides that a franchise
is subject to amendment, alteration or repeal by the Congress when the
Casanovas v. Hord GR No. 3173, March 22, 1907 public interest so requires. However, it cannot be denied that the said
Facts: In 1987, the Spanish Government, in accordance with the provisions 1969 assessment appears to be highly controversial. It had reason not to
pay income tax because of the tax exemption its franchise. For this
of the royal decree of May 14, 1867, granted J. Casanovas certain mines in
reason, it should be liable only for tax proper and should not be held liable
the province of Ambos, Camarines, of which mines the latter is now the
owner. These were validly perfected mining concessions prior to April 11, for surcharge and interest.
1899 is conceded. They were so considered by the CIR and were by him
said to fall within the provisions of Sec. 134 of Act. 1189. The
Commissioner Hord, imposed upon these properties the tax mentioned in Tolentino v. Secretary of Finance GR No. 115455, October 30, 1995
Sec. 134, which Casanovas paid under protest. Issue: W/N Sec. 134 of Act
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Facts: Arturo Tolentino are questioning the constitutionality of RA 7716


otherwise known as the Expanded Value Added Tax (EVAT) Law. Tolentino
averred that this revenue bill did not exclusively originate from the House
of Representatives as required by Section 24, Article 6 of the Constitution.
Even though RA 7716 originated as HB 11197 and that it passed the 3
readings in the HoR, the same did not complete the 3 readings in Senate
for after the 1st reading it was referred to the Senate Ways & Means
Committee thereafter Senate passed its own version known as Senate Bill
1630. Tolentino averred that what Senate could have done is amend HB
11197 by striking out its text and substituting it with the text of SB 1630 in
that way the bill remains a House Bill and the Senate version just
becomes the text (only the text) of the HB. Issue: W/N the EVAT law is
procedurally infirm. Held: No. By a 9-6 vote, the Supreme Court rejected
the challenge, holding that such consolidation was consistent with the
power of the Senate to propose or concur with amendments to the
version originated in the HoR. What the Constitution simply means,
according to the 9 justices, is that the initiative must come from the HoR.
Note also that there were several instances before where Senate passed
its own version rather than having the HoR version as far as revenue and
other such bills are concerned. This practice of amendment by
substitution has always been accepted. The proposition of Tolentino
concerns a mere matter of form. There is no showing that it would make a
significant difference if Senate were to adopt his over what has been
done.
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