G.R. No. L-9141 - Republic vs. Vda. de Ferdez

The case involves the testate estate of Olimpio Fernandez, deceased, as the respondent, and Angelina Oasan Vda de Fernandez, Priscilla O. Fernandez, and Estela O. Fernandez as the appellants. The Republic of the Philippines is also a claimant and appellee.
Olimpio Fernandez and his wife Angelina had a net worth of P8,600 as of December 8, 1941.
During the Japanese occupation, the spouses acquired several properties, increasing their net worth to P31,489 by the time of Olimpio’s death on February 11, 1945.

The Collector of Internal Revenue assessed a War Profits Tax amounting to P7,614.60 against the estate of Olimpio Fernandez under Republic Act No. 55 (War Profits Tax Law).
The administratrix of the estate refused to pay the tax, leading to litigation.
The Court of Tax Appeals ruled in favor of the validity and legality of the tax assessment.
The administratrix appealed the decision to the Supreme Court, challenging the assessment on constitutional and legal grounds.

Whether the War Profits Tax Law (Republic Act No. 55) is unconstitutional for being retroactive and thus violating the due process clause of the Constitution.

Whether the War Profits Tax Law is inapplicable to the estate of Olimpio Fernandez because the law taxes individuals and he was deceased at the time of enactment.

Whether the separate taxation of the estate of Olimpio Fernandez distinct from his wife’s estate is proper since he died before the law was passed.