Case Digest (G.R. No. 205045) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
These consolidated petitions, G.R. Nos. 205045 & 205723, involve the Commissioner of Internal Revenue (petitioner) and San Miguel Corporation (respondent) and center on the excise tax classification of respondent’s beer product, “San Mig Light.” On October 19, 1999, San Miguel Corporation sought BIR authority to register and produce “San Mig Light” as a new brand of fermented liquor subject to the lower excise rate under Section 143 of the 1997 National Internal Revenue Code, as amended by Republic Act No. 8240. The BIR granted registration on October 27, 1999, and respondent paid excise taxes accordingly. On May 28, 2002, the BIR issued a Notice of Discrepancy reclassifying “San Mig Light” as a variant of an existing brand and assessed deficiency taxes of over ₱824 million for 1999–April 2002. After conferences and protests, the BIR issued formal demand letters in April and May 2004, assessing an aggregate of over ₱900 million for removals through January 2004. Respondent paid Case Digest (G.R. No. 205045) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Consolidation
- Commissioner of Internal Revenue (CIR) vs. San Miguel Corporation (SMC).
- Consolidated Supreme Court petitions: G.R. Nos. 205045 & 205723, challenging CTA En Banc decisions on refund claims and deficiency assessments in CTA Cases No. 7052, 7053, 7405, and 7708.
- Registration and Early Classification of “San Mig Light”
- Oct. 19, 1999: SMC requested BIR to register “San Mig Light” for manufacture, taxed at ₱12.15/L as a new brand. Oct. 27, 1999: BIR granted registration for internal-revenue purposes.
- Nov. 3, 1999 & Feb. 7, 2002: SMC advised suggested net retail price ₱21.15/L; BIR confirmed classification as a new brand (medium-priced at ₱9.15/L).
- Notice of Discrepancy and Assessments
- May 28, 2002: BIR issued Notice of Discrepancy reclassifying “San Mig Light” as a variant of existing brands, imposing higher rate (₱19.91/L for 1999 plus increments); demanded ₱824.75 million deficiency.
- Jan.–May 2004: Series of Preliminary Assessment Notices (PANs), Notices of Discrepancy, Formal Letters of Demand, and Final Assessment Notices (FANs) for deficiency taxes totaling approx. ₱906.9 million. SMC filed protests.
- Court of Tax Appeals Proceedings and Refund Claims
- Sept. 2004: SMC filed CTA Cases 7052 & 7053 to contest FANs; paid excise tax at ₱13.61/L from Feb. 1, 2004 under protest.
- Dec. 28, 2005: SMC filed first refund claim (₱782.24 million for Feb. 2, 2004–Nov. 30, 2005); Jan. 31, 2006: CTA Case 7405 filed; later consolidated with 7052 & 7053.
- Oct. 18, 2011: CTA First Division granted 7052/7053 and partially 7405, ordering refund/credit of ₱781.51 million. Oct. 24, 2012: CTA En Banc affirmed.
- Aug. 30, 2007: SMC filed second refund claim (₱926.39 million for Dec. 1, 2005–Jul. 31, 2007); CTA Case 7708 filed Nov. 27, 2007. Jan. 7, 2011: CTA Third Division partially granted, ordering ₱926.17 million refund/credit. Sept. 20, 2012: CTA En Banc affirmed.
Issues:
- Discovery and Production of Documents
- May a Rule 27 motion for production of documents be filed after trial court judgment?
- Did the CIR show “good cause” and satisfy Rule 27 requisites?
- Classification of “San Mig Light” Under Sec. 143, NIRC
- Is “San Mig Light” a new brand or a variant of “San Miguel Pale Pilsen”?
- Does the “classification freeze” in Republic Act No. 9334 bar BIR reclassification of brands introduced Jan. 1, 1997–Dec. 31, 2003 except by act of Congress?
- Are the deficiency assessments based on BIR’s reclassification valid?
- Entitlement to Refund
- Is SMC entitled to refund or tax credit certificates for excise taxes (₱781.51 million for Feb. 2, 2004–Nov. 30, 2005; ₱926.17 million for Dec. 1, 2005–Jul. 31, 2007) under Sections 229 & 204, NIRC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)