G.R. No. 210836 - Chevron Philippines, Inc. vs. Commissioner of Internal Revenue

Chevron Philippines, Inc. (Chevron) is engaged in the importation, distribution, marketing, and sale of petroleum products.
During the period from August 2007 to December 2007, Chevron imported petroleum products which it subsequently sold to Clark Development Corporation (CDC), a tax‐exempt entity.
CDC is an entity created to manage the Clark Special Economic Zone and is exempt from both direct and indirect taxes under relevant laws (e.g., Section 24 of Republic Act No. 7916 and Section 15 of Republic Act No. 9400).

As the importer and statutory taxpayer, Chevron was obligated to pay excise taxes under Section 131 of the National Internal Revenue Code (NIRC) at the time of importation.
Notably, Chevron did not pass on the excise taxes to CDC upon sale, since CDC is among the entities exempt from excise tax under Section 135(c) of the NIRC.
In June 2009, Chevron filed an administrative claim for a tax refund or issuance of a tax credit certificate in the amount of ₱6,542,400.00, representing the excise taxes paid.

After the Commissioner of Internal Revenue (CIR) did not act on its claim, Chevron elevated the matter to the Court of Tax Appeals (CTA) by filing a petition for review.
The CTA First Division denied the refund/credit claim on July 31, 2012, and later its Motion for Reconsideration was also denied in November 2012.
Chevron subsequently appealed to the CTA En Banc, which in its September 30, 2013 decision, reaffirmed the denial based on the interpretation of Section 135.
Chevron sought reconsideration based on the reversal of the earlier Pilipinas Shell decision by the CTA First Division on February 19, 2014.
Finally, Chevron filed a Motion for Reconsideration with the Supreme Court, which was initially denied by the Court’s Second Division on March 19, 2014 for lack of reversible error, before the case was referred to the Court En Banc and eventually decided on September 1, 2015.

Whether Chevron, as the importer and statutory taxpayer, is entitled to a refund or the issuance of a tax credit certificate for the excise taxes paid on petroleum products subsequently sold to CDC.
Whether the exemption provided under Section 135(c) of the NIRC, which benefits the petroleum products when sold to tax-exempt entities, triggers the right of the statutory taxpayer to claim a refund under Section 204 of the NIRC.
Whether the fact that CDC is exempt from both direct and indirect taxes should preclude Chevron from claiming a refund, given that the exemption was primarily intended to benefit the property (i.e., the petroleum products) and not the buyer.