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This case has been cited 3 times or more.

	GR No. 175188 2015-07-15	CIR v. LA TONDEÑA DISTILLERS DEL CASTILLO, J.
In closing, we must stress that taxes must not be imposed beyond what the law expressly and clearly declares as tax laws must be construed strictly against the State and liberally in favor of the taxpayer.[45]
	GR No. 211666 2015-02-25	REPUBLIC v. ARLENE R. SORIANO PERALTA, J.
Yet, a perusal of the provision cited above does not explicitly impute the obligation to pay the documentary stamp tax on the seller. In fact, according to the BIR, all the parties to a transaction are primarily liable for the documentary stamp tax, as provided by Section 2 of BIR Revenue Regulations No. 9-2000, which reads:[26]
	GR No. 166018 2014-06-04	KONG v. CIR LEONARDO-DE CASTRO, J.
DST is an excise tax on the exercise of a right or privilege to transfer obligations, rights or properties incident thereto.[23] Under Section 173 of the 1997 Tax Code, the persons primarily liable for the payment of the DST are those (1) making, (2) signing, (3) issuing, (4) accepting, or (5) transferring the taxable documents, instruments or papers.[24]