This case has been cited 3 times or more.
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2014-06-04 |
MENDOZA, J. |
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| It is a well-settled rule that the government cannot be estopped by the mistakes, errors or omissions of its agents.[32] It has been specifically held that estoppel does not apply to the government, especially on matters of taxation. Taxes are the nation's lifeblood through which government agencies continue to operate and with which the State discharges its functions for the welfare of its constituents.[33] Thus, the government cannot be estopped from collecting taxes by the mistake, negligence, or omission of its agents. Upon taxation depends the ability of the government to serve the people for whose benefit taxes are collected. To safeguard such interest, neglect or omission of government officials entrusted with the collection of taxes should not be allowed to bring harm or detriment to the people.[34] | |||||
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2010-07-28 |
PEREZ, J. |
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| Under RR 5-2000, a TDM or a Tax Debit Memo "shall serve as the official receipt from the BIR evidencing a taxpayer's payment or satisfaction of his tax obligation." Until the Center's cancellation of the TCCs assigned in its favor, Petron was, in fact, never questioned nor assessed for deficiency or delinquency in the payment of its excise taxes thru the use of the same TCCs.[60] Even prescinding from the CTA July 23, 1999 decision in C.T.A. Case No. 5657 which remains on appeal before the Court of Appeals, we find that Petron had every right to rely on the validity of the subject TCCs, the Center's approval of the deeds of assignment the grantees executed over the same and the BIR's acceptance of its use thereof in payment of its excise taxes. While the Government cannot, concededly, be estopped from collecting taxes by the mistake, negligence, or omission of its agents,[61] the Court's ruling in the Pilipinas Shell case is to the effect that an assignee's status as a transferee in good faith and for value provides ample protection from the adverse findings subsequently made by the Center.[62] | |||||
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2008-02-13 |
CORONA, J. |
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| Moreover, it is a well-settled rule in statutory construction that a subsequent general law does not repeal a prior special law on the same subject unless it clearly appears that the legislature has intended by the latter general act to modify or repeal the earlier special law. Generalia specialibus non derogant (a general law does not nullify a specific or special law).[102] This is so even if the provisions of the general law are sufficiently comprehensive to include what was set forth in the special act.[103] The special act and the general law must stand together, one as the law of the particular subject and the other as the law of general application.[104] The special law must be taken as intended to constitute an exception to, or a qualification of, the general act or provision.[105] | |||||