Case Digest (G.R. No. L-6355-56) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pastor M. Endencia and Fernando Jugo v. Saturnino David, decided on August 31, 1953, the petitioners, Associate Justice Pastor M. Endencia and Presiding Justice (later Associate Justice) Fernando Jugo of the Court of Appeals, sought refund of income taxes withheld from their salaries. Both had paid income tax under Republic Act No. 590, specifically Section 13, which purported to declare that no public officer’s salary was exempt from income tax and that payment thereof was “not a diminution of his compensation.” The Court of First Instance of Manila, with Judge Higinio B. Macadaeg presiding, ruled Section 13 unconstitutional under Article VIII, Section 9 of the 1935 Philippine Constitution, holding that taxing a judicial officer’s salary diminished compensation and ordering refunds of ₱1,744.45 to Endencia and ₱2,345.46 to Jugo. The Collector of Internal Revenue, Saturnino David, appealed, challenging the lower court’s reliance on Perfecto v. Meer (85 Phil. 552) and arguing Case Digest (G.R. No. L-6355-56) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Justice Pastor M. Endencia and Justice Fernando Jugo each paid income tax on their 1950–1951 salaries as appellate and Supreme Court justices and filed suit for refund (P1,744.45 for Endencia; P2,345.46 for Jugo).
- The Court of First Instance of Manila declared Section 13 of Republic Act No. 590 unconstitutional and ordered Collector Saturnino David to refund the withheld amounts without pronouncement as to costs.
- Constitutional and Legislative Context
- Article VIII, Section 9 of the 1935 Constitution provides that judicial salaries “shall not be diminished during their continuance in office.”
- In Perfecto v. Meer (85 Phil. 552), this Court held that any income tax on judicial salaries violated that non-diminution clause.
- Republic Act No. 590 (Section 13) declared no public officer’s salary exempt from income tax and that such payment “is hereby declared not to be a diminution of his compensation fixed by the Constitution or by law.”
Issues:
- Can Section 13 of RA 590 validly authorize the collection of income tax on judicial salaries without violating the Constitution’s non-diminution clause?
- May the Legislature, by statute, interpret or override a constitutional provision already definitively construed by the Supreme Court?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)