Facts:
Revenue Regulations No. 4-2014 was issued on March 3, 2014 and took effect on April 5, 2014; it was promulgated by then
Secretary Cesar V. Purisima of the
Department of Finance upon recommendation of then
Commissioner Kim S. Jacinto-Henares of the
Bureau of Internal Revenue and required self‑employed professionals to register, pay an annual registration fee, submit an affidavit of rates and manner of billing, register books of account and official appointment books showing client names and appointment dates/times, and issue receipts even for pro bono services. Three days after the regulation took effect representative professional organizations, led by the
Integrated Bar of the Philippines, filed a Petition for Prohibition and Mandamus, later joined by the
Association of Small Accounting Practitioners in the Philippines, Inc. and intervened in by the
Philippine College of Physicians,
Philippine Medical Association, Inc., and
Philippine Dental Association; the Office of the Solicitor General initially defended respondents but later conceded that portions of the regulation might be unconstitutional. This Court issued temporary restraining orders in April and thereafter consolidated the petitions, received consolidated comments and memoranda from the parties, and gave due course to the petitions on July 26, 2016; the litigation culminated in this en banc decision dated April 18, 2023 in which petitioners challenged the regulation as ultra vires, violative of professional ethics, and an unreasonable intrusion into the
right to privacy of professionals and their clients.
Issues:
Whether the petitions presented a justiciable controversy and whether petitioners had standing to invoke the Court’s original jurisdiction to review
Revenue Regulations No. 4-2014? Whether respondents exceeded their statutory and constitutional authority in issuing
Revenue Regulations No. 4-2014, specifically in requiring (a) the submission of an affidavit indicating rates, manner of billing, and factors considered in fixing service fees, and (b) the registration of appointment books containing client names and appointment dates and times? Whether the mandatory registration of appointment books and the affidavit requirement unreasonably invaded the
right to privacy and violated professional confidentiality and ethical standards of the professions involved?
Ruling:
Ratio:
Doctrine: