Case Digest (G.R. No. 172238) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 17, 2018, the Supreme Court rendered its decision in International Container Terminal Services, Inc. v. City of Manila (G.R. No. 185622), arising from ICTSI’s 1999 business‐license renewal in Manila. ICTSI was assessed two local business taxes under Manila Ordinance No. 7794: a 0.75% contractors’ tax (Section 18) and a newly imposed 0.5% levy (Section 21(A), as amended by Ordinance No. 7807). After paying the additional assessment under protest by letter dated July 15, 1999, ICTSI filed a petition for certiorari in the Regional Trial Court (RTC) when the City Treasurer failed to act. The RTC dismissed the case for noncompliance with Section 187 of the Local Government Code (LGC), but the Court of Appeals reversed and remanded. Meanwhile, ICTSI continued paying the disputed tax and sent refund claims to the City Treasurer on June 17, 2003; August 18, 2005; and January 10, 2007, invoking Section 196(LGC). The Court of Tax Appeals (CTA) Second Division in May 2006 declar Case Digest (G.R. No. 172238) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transaction
- International Container Terminal Services, Inc. (ICTSI) renewed its 1999 business license in Manila and was assessed two local business taxes pursuant to:
- Section 18 of Manila Ordinance No. 7794 (contractors’ tax at 75% of 1% of gross receipts)
- Section 21(A) of Manila Ordinance No. 7794, as amended by Ordinance No. 7807 (50% of 1% of gross receipts)
- ICTSI paid both assessments under protest and sought administrative relief with the City Treasurer but received no decision within the reglementary period.
- Procedural History
- ICTSI filed a Petition for Certiorari with the Regional Trial Court (RTC) of Manila, which was dismissed for failure to comply with Section 187 of the Local Government Code. The Court of Appeals reversed and remanded.
- While the case was pending, Manila continued collecting both taxes as a condition for permit issuance. ICTSI sent letters (June 17, 2003; August 18, 2005; January 10, 2007) claiming refunds under Section 196 of the Local Government Code.
- The RTC dismissed ICTSI’s Amended and Supplemental Petition for failing to avail of the remedy under Section 195; ICTSI appealed to the Court of Tax Appeals (CTA).
- CTA Second Division (May 17, 2006) found direct double taxation, ordered refund of ₱6,224,250 (first three quarters of 1999), but denied refunds for subsequent periods for lack of protest proof. CTA Second Division (Feb. 22, 2007) denied motions for reconsideration.
- CTA En Banc (Sept. 5, 2008) dismissed ICTSI’s petition: ICTSI had invoked Section 195 remedy, not Section 196, and failed to file timely written protests for each assessment. A concurring and dissenting opinion would have partially granted the refund. CTA En Banc denied reconsideration (Dec. 12, 2008).
- ICTSI filed a Petition for Review on Certiorari with the Supreme Court under Rule 45, challenging CTA En Banc’s decision and resolution.
Issues:
- Whether the RTC acquired jurisdiction over ICTSI’s refund claims for post–third quarter 1999 periods despite alleged nonpayment of additional docket fees.
- Whether ICTSI’s refund claims from the fourth quarter of 1999 onwards are governed by Section 195 or Section 196 of the Local Government Code.
- Whether ICTSI complied with the procedural requirements entitling it to a refund.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)