Case Digest (G.R. No. 199669) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Southern Luzon Drug Corporation (petitioner), a domestic drugstore operator, filed on February 26, 2008 a Petition for Prohibition with Application for Temporary Restraining Order and/or Writ of Preliminary Injunction before the Court of Appeals (CA) in CA-G.R. SP No. 102486. It sought to enjoin the Department of Social Welfare and Development (DSWD), the National Council for the Welfare of Disabled Persons (NCWDP, now National Council on Disability Affairs), the Department of Finance (DOF) and the Bureau of Internal Revenue (BIR) (collectively, respondents) from implementing: (a) Section 4(a) of Republic Act No. 9257 (Expanded Senior Citizens Act of 2003), which mandates a 20% discount on medicines for senior citizens and allows covered establishments to claim the discount as a tax deduction; and (b) Section 32 of Republic Act No. 9442 (amending the Magna Carta for Disabled Persons by inserting a similar 20% discount for persons with disability, likewise treated as a tax deduct Case Digest (G.R. No. 199669) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Southern Luzon Drug Corporation (petitioner), a domestic corporation operating drugstores, filed before the Court of Appeals (CA) a Petition for Prohibition with Application for TRO and/or Writ of Preliminary Injunction, assailing the implementation of:
- The CA dismissed the petition on June 17, 2011, and denied petitioner’s motion for reconsideration on November 25, 2011. Petitioner then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
- Legislative and Regulatory Background
- R.A. No. 7432 (1992) granted senior citizens aged ≥ 60 a 20 % discount on medicines, recoverable by establishments as tax credit subject to an income ceiling.
- R.A. No. 9257 (2004) removed the income ceiling, retained the 20 % discount, and modified its tax treatment to a deduction from gross income based on net cost of goods sold. DSWD issued IRR in May 2004, confirming tax deduction treatment, subject to BIR/DOF Revenue Regulations.
- R.A. No. 7277 (1992) codified Magna Carta for Disabled Persons; R.A. No. 9442 (2007) amended it by inserting Chapter 8 granting PWDs a 20 % discount on medicines, likewise recoverable as tax deduction. A joint IRR was promulgated by DSWD and other agencies.
- Prior Jurisprudence
- In Carlos Superdrug Corp. v. DSWD (G.R. No. 166494, 2007), the Supreme Court upheld Section 4(a) of R.A. 9257 as a valid exercise of police power, rejecting takings and due process/equal protection challenges.
- Petitioner argued the same issues before the CA in 2011, which invoked stare decisis and jurisdictional grounds to dismiss, and held prohibition improper for constitutional challenge.
Issues:
- Whether a Petition for Prohibition before the CA is a proper remedy to assail the constitutionality of Sections 4(a) of R.A. 9257 and 32 of R.A. 9442.
- Whether the Supreme Court’s ruling in Carlos Superdrug constitutes stare decisis and bars relitigation of the issues.
- Whether the 20 % discount and its tax-deduction treatment are a valid exercise of police power or an invalid exercise of eminent domain requiring just compensation.
- Whether elimination of the senior-citizen income ceiling and grant of identical 20 % discount to all senior citizens and PWDs violates equal protection.
- Whether definitions of “disability” and “persons with disability” in R.A. 9442 and its IRR are vague, depriving PWDs and establishments of due process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)