Case Digest (G.R. No. L-13250) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Collector of Internal Revenue vs. Antonio Campos Rueda (G.R. No. L-13250, October 29, 1971), the Collector of Internal Revenue assessed respondent Antonio Campos Rueda, administrator of the estate of Maria de la Estrella Soriano Vda. de Cerdeira, for P161,874.95 in deficiency estate and inheritance taxes on intangible personal properties located in the Philippines. Maria Cerdeira, a Spanish national by marriage, resided in Tangier, Morocco from 1931 until her death on January 2, 1955, and owned bonds and shares in the Philippines. On September 29, 1955, Rueda filed a provisional return and paid initial assessments; on November 17, 1955, he filed an amended return claiming exemption for intangible property under Section 122 of the National Internal Revenue Code (1939). The Collector denied the exemption, arguing that (1) Tangier was not a “foreign country” under Section 122 because it lacked international personality, and (2) Tangier law did not grant the required reciprocal t Case Digest (G.R. No. L-13250) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioner: Collector of Internal Revenue.
- Respondent: Antonio Campos Rueda, administrator of the estate of Maria de la Estrella Soriano Vda. de Cerdeira.
- Deceased and Properties
- Deceased was a Spanish national by marriage, resident of Tangier, Morocco (1931–1955).
- She owned intangible personal properties situated in the Philippines.
- Procedural History
- September 29, 1955: Provisional estate and inheritance tax return filed; initial assessment of ₱269,383.96 paid.
- November 17–23, 1955: Amended return claimed exemption on ₱396,308.90; assessment of ₱469,665.24 paid.
- January 11, 1956: Collector denied exemption and demanded ₱239,439.49.
- February 8, 1956: Petitioner sought reconsideration; May 5, 1956: request denied and deficiency reduced to ₱161,874.95.
- Elevated to Court of Tax Appeals (CTA); CTA held exemption applies, finding reciprocity and no statehood requirement.
- May 30, 1962: Supreme Court remanded to CTA to determine if Tangier laws cover “intangible personal property.”
- September 9, 1963: CTA admitted evidence showing Tangier exempted “movables, corporeal or incorporeal.”
- July 29, 1969: Case deemed submitted; prior January 6, 1958 De Lara decision held statehood not required.
Issues:
- Interpretation of “foreign country” under Section 122
- Must a foreign country possess statehood or international personality to qualify for the exemption?
- Qualification of Tangier
- Does Tangier, lacking full international personality, qualify as a “foreign country” under Section 122?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)