Case Digest (G.R. No. 81158)
Facts:
Coca-Cola Bottlers Philippines, Inc. v. City of Manila, G.R. No. 197561, April 07, 2014, Supreme Court Third Division, Peralta, J., writing for the Court. Petitioner is Coca‑Cola Bottlers Philippines, Inc.; respondents are the City of Manila and several city officers sued in their official capacities as named in the caption.The litigation began with the Regional Trial Court of Manila (RTC‑Manila) Decision dated September 28, 2001 in Civil Case No. 00‑97081, which found that petitioner had been double‑taxed and ordered respondents to either refund or credit the amount of P3,036,887.33 under Section 21 of the Revenue Code of Manila. Respondents appealed to the Court of Appeals. The Court of Appeals dismissed respondents' appeal in a Resolution of April 9, 2003 for being improperly brought under the Rules; it affirmed that disposition in a February 28, 2005 Resolution.
Respondents sought further review before this Court; on February 10, 2010 the Supreme Court denied their petition for review and affirmed the Court of Appeals' resolutions, a disposition reflected in an Entry of Judgment issued by the Clerk on May 12, 2010 and declared final and executory as of March 10, 2010.
Petitioner moved for execution of the RTC judgment on June 3, 2010; the RTC granted the motion on June 11, 2010 and the Branch Clerk issued a writ of execution on June 15, 2010. Respondents filed a Motion to Quash the writ; the RTC granted that motion on December 22, 2010, reasoning the motion was prejudicial to respondents and would hamper City projects, and denied petitioner's motion for reconsideration on June 21, 2011 on the ground that tax refund/credit involve public funds and that enforcement should follow P.D. No. 1445 and Administrative Circular No. 10‑2000.
Petitioner filed this Rule 45 petition for review on certiorari, challenging the RTC's quashal of the writ of execution and asserting (...(Subscriber-Only)
Issues:
- Was the issuance of the writ of execution proper to enforce the RTC judgment ordering the City of Manila to refund or issue a tax credit of P3,036,887.33?
- Do Administrative Circular No. 10‑2000 and P.D. No. 1445 (Government Auditing Code) bar execution or otherwise control enforcement of a judicially‑affirmed tax refund/tax credit?
- Did the RTC’s Order quashing the writ of execution effectively reverse th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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