Case Digest (G.R. No. L-17931) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Casco Philippine Chemical Co., Inc. v. Hon. Pedro Gimenez and Hon. Ismael Mathay (G.R. No. L-17931, February 28, 1963), the petitioner, Casco Philippine Chemical Co., Inc., a manufacturer of synthetic resin glues used by plywood and hardboard producers, purchased foreign exchange on several occasions in November and December 1959 for the importation of urea and formaldehyde, paying a margin fee totaling ₱33,765.42 under Republic Act No. 2609 (Foreign Exchange Margin Fee Law) as implemented by Central Bank Circular No. 95 (July 1, 1959). In May 1960, petitioner made an additional foreign exchange purchase for the same raw materials, paying ₱6,345.72. Relying on Monetary Board Resolution No. 1529 (November 3, 1959), which declared the separate importation of urea and formaldehyde exempt from the margin fee, petitioner applied for refunds of both payments. Although the Central Bank issued vouchers approving the refunds, the Auditor of the Central Bank refused to pass them, findi Case Digest (G.R. No. L-17931) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Regulatory and statutory background
- Republic Act No. 2609 (Foreign Exchange Margin Fee Law) empowered the Monetary Board to fix a margin fee on foreign exchange transactions.
- On July 1, 1959, the Central Bank of the Philippines issued Circular No. 95 imposing a uniform 25% margin fee; a subsequent memorandum set forth procedures for exemption applications.
- Petitioner’s importations and refund applications
- November–December 1959: Casco Philippine Chemical Co., Inc. purchased foreign exchange for the importation of urea and formaldehyde (raw materials for synthetic resin glues) and paid P33,765.42 in margin fees.
- May 1960: The petitioner made a similar purchase and paid P6,345.72 in fees. Refund requests for both sums were filed, relying on Monetary Board Resolution No. 1529 (Nov. 3, 1959) exempting “urea formaldehyde.”
- The Central Bank auditor refused to pass the refund vouchers, holding that Section 2, paragraph XVIII of RA 2609 exempts only “urea formaldehyde” (the finished resin), not the separate chemicals. The Auditor General affirmed that denial.
Issues:
- Statutory scope of exemption
- Whether the phrase “urea formaldehyde for the manufacture of plywood and hardboard when imported by and for the exclusive use of end-users” in Section 2, paragraph XVIII of RA 2609 covers separate importations of (a) urea and (b) formaldehyde.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)