Facts:

• The case concerns the intestate estate of Tomas Siy Cong Bieng, also known as Siy Chong Lin, who has passed away.
• Siy Chong Keng serves as the administrator of the estate and is involved in special proceedings No. 41435 in the Court of First Instance of Manila.
• On October 2, 1933, the court ordered the administrator to pay an inheritance tax based on the estate's value as appraised by commissioners.
• The Collector of Internal Revenue, represented by the Solicitor-General, filed a motion for reconsideration, claiming the court's decision was based on a mistaken belief that the Collector could not challenge the appraised value.
• The Collector argued he was not notified of the commissioners' report and that the law mandates the inheritance tax to be assessed based on the minimum value in the tax rolls.
• The Collector assessed the inheritance tax at P57,914.81, including a 25% surcharge and interest, which the administrator did not pay.
• The lower court denied the motion for reconsideration, prompting the Collector of Internal Revenue to appeal.

Issue:

• (Unlock)

Ruling:

• Yes, the lower court erred in holding that the inheritance tax should be determined based on the commissioners' appraisal.
• Yes, the lower court erred in holding that the Collector of Internal Revenue had been notified of the commissioners' report.
• Yes, the lo...(Unlock)

Ratio:

• The Supreme Court determined that the Collector of Internal Revenue is not bound by the appraisals made by the commissioners, as he did not participate in their deliberations.
• The law does not require the Collector to engage in the appraisal process or to appeal the commissioners' report.
• The court highlighted that the appraisal's purpose is to facilitate equitable estate distribution and deter...continue reading