Case Digest (G.R. No. L-59431)
Facts:
In Sison v. Ancheta, G.R. No. L-59431, decided on July 25, 1984, Antero M. Sison Jr. filed an original petition for declaratory relief and prohibition with the Supreme Court in Manila against Ruben B. Ancheta, Acting Commissioner of Internal Revenue, Deputy Commissioners Romulo Villa and Tomas Toledo, Minister of Budget Manuel Alba, Commissioner on Audit Francisco Tantuico, and Minister of Finance Cesar Virata. Petitioner challenged the validity of Section 1 of Batas Pambansa Blg. 135, which amended Section 21 of the 1977 National Internal Revenue Code by imposing a graduated tax schedule on taxable compensation income ranging from 0% to 35% and a separate, higher schedule on taxable net income of professionals and businesspersons ranging from 5% to 60%. Sison alleged that the higher rates on business and professional earnings, as compared with those on fixed or salaried income, amounted to arbitrary class legislation, violated the due process and equal protection clauses of theCase Digest (G.R. No. L-59431)
Facts:
- Parties
- Petitioner: Antero M. Sison, Jr., taxpayer.
- Respondents: Ruben B. Ancheta (Acting Commissioner, BIR), Romulo Villa and Tomas Toledo (Deputy Commissioners, BIR), Manuel Alba (Minister of Budget), Francisco Tantuico (Chairman, Commission on Audit), Cesar E. A. Virata (Minister of Finance).
- Challenged Statute
- Batas Pambansa Blg. 135, § 1, amending § 21 of the National Internal Revenue Code (1977).
- Imposes progressive tax rates on:
- Taxable compensation income (0% up to 35% on amounts over ₱500,000).
- Taxable net income of professionals and businesses (5% up to 60% on amounts over ₱500,000).
- Allegations and Procedural History
- Petitioner claims the higher net-income rates discriminate against professionals/businesses versus fixed-income taxpayers, violating equal protection, due process, and uniformity in taxation.
- On January 26, 1982, the Supreme Court required respondents to answer; after extensions, an answer was filed May 28, 1982.
- Respondents admitted the basic facts, denied the legal conclusions, affirmed the statute’s validity, and prayed for dismissal.
Issues:
- Does imposing higher tax rates on professional/business net income than on compensation income violate the Due Process Clause?
- Does such a classification infringe the Equal Protection Clause?
- Does the challenged provision contravene the constitutional requirement of uniform and equitable taxation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)