Case Digest (G.R. No. 38332) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Bank of the Philippine Islands v. Posadas, G.R. No. 34583, decided October 22, 1931, the Bank of the Philippine Islands, as administrator of the estate of the late Adolphe Oscar Schuetze, sued Juan Posadas, Jr., Collector of Internal Revenue, to recover ₱1,209 paid under protest as inheritance tax on ₱20,150, the proceeds of a life-insurance policy. Schuetze, a German national, first arrived in the Philippines in 1890, married Rosario Gelano on January 16, 1914, and died in Manila on February 2, 1928. The Bank was appointed testamentary administrator on May 24, 1928. Policy No. 194538 for $10,000 was issued January 14, 1913, naming Schuetze’s estate as sole beneficiary; the first premium (Jan. 1913–Jan. 1914) was paid before marriage, and subsequent premiums (1914–1928) were paid from conjugal funds. The insurer ultimately paid ₱20,150 in Manila to the Bank, which turned it over to Mrs. Schuetze. On July 6, 1929, the Collector assessed ₱1,209 inheritance tax under Section Case Digest (G.R. No. 38332) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- The Bank of the Philippine Islands (BPI), as administrator of the estate of the late Adolphe Oscar Schuetze, filed a complaint for refund of ₱1,209 paid under protest as inheritance tax on ₱20,150 insurance proceeds.
- The Court of First Instance of Manila absolved Collector Juan Posadas, Jr. and dismissed the complaint. BPI appealed.
- Agreed Stipulated Facts
- Adolphe Oscar Schuetze (deceased) married Rosario Gelano on January 16, 1914; made a will in Germany (December 3, 1927) naming his widow universal heir; died in Manila on February 2, 1928.
- Life-insurance policy No. 194538 for $10,000 was issued January 14, 1913 by Sun Life Assurance Co. of Canada (Manila branch), transferred in 1918 to the London branch. The estate of Schuetze was named sole beneficiary.
- Premiums: the first year’s premium (Jan 1913–Jan 1914) was paid with the deceased’s separate funds; all subsequent premiums (Jan 1914 until death) were paid from conjugal funds.
- On July 13, 1928, BPI received ₱20,150 (net proceeds) from the insurer, delivered it to the widow, then was required by the Collector to pay ₱1,209 inheritance tax under Sec. 1536, Administrative Code.
Issues:
- Are the proceeds of a life-insurance policy payable to the insured’s estate, on which premiums were paid from conjugal funds (except first premium), community or separate property?
- Does the Collector have authority under Sec. 1536, Administrative Code, to levy inheritance tax on such proceeds (or on one-half community share) when received and administered in the Philippines?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)