Title
Republic vs. Mambulao Lumber Co.
Case
G.R. No. L-17725
Decision Date
Feb 28, 1962
Mambulao Lumber Co. sought to offset reforestation charges against forest charges, but the Supreme Court ruled that reforestation charges, as taxes, cannot be set off against liabilities owed to the government.

Case Digest (G.R. No. L-17725)
Expanded Legal Reasoning Model

Facts:

  • Background and Trial Court Decision
    • Republic of the Philippines (plaintiff-appellee) sued Mambulao Lumber Company and General Insurance & Surety Corporation (defendants-appellants) in Civil Case No. 34100, CFI Manila.
    • The trial court ordered defendants to pay P4,802.37 with 6% interest from the filing of the complaint until fully paid, plus costs.
  • Admitted Liabilities for Forest Charges
    • First cause of action: P587.37 (forest charges for September 10, 1952 to May 24, 1953), secured by a bond dated July 29, 1953.
    • Second cause of action: P286.70, secured by a bond dated November 27, 1953.
    • Third cause of action: P3,928.30, secured by a bond dated July 20, 1954.
    • Aggregate forest charges admitted by defendants: P4,802.37.
  • Defense Based on Reforestation Charges
    • Payments claimed by Mambulao Lumber Company as reforestation charges under Republic Act No. 115:
      • P927.08 for April 30, 1947 to June 24, 1948.
      • P8,200.52 for July 21, 1948 to December 29, 1956.
      • Total claimed reforestation charges: P9,127.50.
    • Statutory basis: Section 1, RA 115 imposed additional charges (₱0.50/m³ for groups I–II; ₱0.40/m³ for groups III–IV) to constitute a “Reforestation Fund,” to be expended at the Director of Forestry’s discretion for reforestation/afforestation.
    • Correspondence: On February 21, 1957, defendant requested credit of P2,988.62 against its account; on March 12, 1957, Director of Forestry declined, citing lack of discretion and DOJ opinion.

Issues:

  • Main Issue
    • Whether the P9,127.50 paid by appellant as reforestation charges may be set off or applied against the P4,802.37 forest charges owed to the Republic of the Philippines.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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