Republic vs. Vda. de Fernandez

Facts:

The dispute arose from an assessment under the War Profits Tax Law (Republic Act No. 55) against the estate of Olimpio Fernandez. The Republic of the Philippines (claimant and appellee) sought P7,614.60 in war profits tax from the estate; the oppositors and appellants are Angelina Oasan Vda. de Fernandez, Priscilla O. Fernandez, and Estela O. Fernandez. At the outbreak of hostilities on December 8, 1941 the spouses Olimpio and Angelina had an admitted net worth of P8,600. During the Japanese occupation, the couple acquired additional real properties, and at the time of Olimpio’s death on February 11, 1945 his net worth was P31,489.

The Collector of Internal Revenue assessed the war profits tax against Olimpio’s estate. The administratrix of the estate refused to pay, and the matter was brought before the Court of Tax Appeals, which sustained the assessment and upheld its validity and legality. The administratrix (oppositors/appellants) appealed the Court of Tax Appeals’ decision to the Supreme Court. The appeal presented constitutional and statut...(Pro-only)

Issues:

• Is the War Profits Tax Law (Republic Act No. 55) unconstitutional as an impermissibly retroactive law in violation of due process/ex post facto principles?
• Can the war profits tax imposed by RA No. 55 be validly assessed against the estate of a decedent who profited during the war but died before the law was enacted?
• May the properties of Olimpio Fernandez be treated as separate from those of his wife for purposes of assessing the war profits tax, giv...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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