Case Digest (G.R. No. L-23794) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On January 29, 1964, the Municipal Board of Ormoc City enacted Ordinance No. 4, Series of 1964, which levied “on any and all productions of centrifugal sugar milled at the Ormoc Sugar Company, Inc. in Ormoc City a municipal tax equivalent to one per centum (1%) per export sale to the United States of America and other foreign countries.” Under protest, Ormoc Sugar Company, Inc. paid P7,087.50 on March 20, 1964 and P5,000 on April 20, 1964, totaling P12,087.50. On June 1, 1964, the company filed a complaint for declaratory relief with the Court of First Instance of Leyte, serving a copy on the Solicitor General. It challenged the ordinance as an unconstitutional export tax prohibited by Section 2287 of the Revised Administrative Code, and as violative of the equal protection clause (Sec. 1[1], Art. III) and the uniformity rule (Sec. 22[1], Art. VI) of the 1935 Constitution. It also argued that Ormoc City lacked authority under Section 15-kk of its charter and Section 2 of Republi Case Digest (G.R. No. L-23794) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ordinance Enactment and Tax Payment
- On January 29, 1964, the Municipal Board of Ormoc City adopted Ordinance No. 4, Series of 1964, imposing a municipal tax of one percent (1%) on any and all productions of centrifugal sugar milled at Ormoc Sugar Company, Inc., “per export sale to the United States of America and other foreign countries.”
- Ormoc Sugar Company, Inc. paid the tax under protest: ₱7,087.50 on March 20, 1964, and ₱5,000 on April 20, 1964, totaling ₱12,087.50.
- Trial Court Proceedings
- On June 1, 1964, Ormoc Sugar Company, Inc. filed a complaint in the Court of First Instance of Leyte against Ormoc City, its Treasurer, Municipal Board, and Mayor, alleging that the ordinance (a) violates the equal protection clause (Art. III, Sec. 1[1]), (b) breaches the uniformity rule of taxation (Art. VI, Sec. 22[1]), (c) constitutes a forbidden export tax under Sec. 2287 of the Revised Administrative Code, and (d) exceeds the city’s taxing power under its charter and R.A. 2264.
- Defendants argued the ordinance was valid under the Local Autonomy Act (R.A. 2264). After pretrial and submission of memoranda, the CFI, on August 6, 1964, upheld the ordinance as constitutional and broadened the city’s taxing power. Ormoc Sugar Company directly appealed to the Supreme Court.
- Legal and Statutory Context
- Section 2287, Revised Administrative Code, prohibits municipal export taxes: “It shall not be in the power of the municipal council to impose a tax in any form…upon goods…out of the same…”
- Republic Act 2264 (Local Autonomy Act), effective June 19, 1959, grants chartered cities authority to levy “just and uniform taxes, licenses or fees.” In Nin Bay Mining Co. v. Municipality of Roxas (L-20125, July 20, 1965), the Court held R.A. 2264 implicitly repealed Sec. 2287.
Issues:
- Whether Ordinance No. 4, Series of 1964, taxing centrifugal sugar exports, violates the equal protection clause (Art. III, Sec. 1[1]).
- Whether the ordinance breaches the uniformity requirement of taxation (Art. VI, Sec. 22[1]).
- Whether the tax imposed is an export tax forbidden by Sec. 2287, Revised Administrative Code, or validly authorized by R.A. 2264.
- Whether Ormoc Sugar Company, Inc. is entitled to interest on the refunded taxes paid under protest.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)