Case Digest (G.R. No. 230138)
Facts:
St. Mary's Academy Caloocan City, Inc. v. Hon. Kim Jacinto S. Henares, G.R. No. 230138, January 13, 2021, Supreme Court Third Division, Leonen, J., writing for the Court. This is a Petition for Review on Certiorari attacking the Court of Appeals' decision that set aside a Regional Trial Court order and resolution declaring certain Bureau of Internal Revenue issuances void as to non‑stock, non‑profit educational institutions.In July 2013 Commissioner of Internal Revenue Kim S. Jacinto‑Henares issued Revenue Memorandum Order No. 20‑2013 (RMO No. 20‑2013) prescribing guidelines for processing tax exemption applications and re‑validation of exemption rulings under Section 30 of the National Internal Revenue Code. In August 2013 she issued Revenue Memorandum Circular No. 52‑2013 (RMC No. 52‑2013) which fixed deadlines for the validity of unused or unissued principal and supplementary receipts/invoices printed before January 18, 2013 and required taxpayers to secure new authority to print after those deadlines.
On November 13, 2013 Revenue District Officer Rene Detablan notified St. Mary’s Academy that its receipts were no longer valid as of October 31, 2013 under RMC No. 52‑2013 and demanded proof of authority to print or threatened penalties. St. Mary’s Academy replied that as a non‑stock, non‑profit educational institution it was tax‑exempt and not required to apply for authority to print, citing Revenue Ruling No. 159‑98 and earlier Department of Finance guidance. Regional Director Gerardo R. Florendo nonetheless advised the academy that RMC No. 52‑2013 covered supplementary receipts the school issued and that it also had to reapply for tax‑exemption under RMO No. 20‑2013.
St. Mary’s Academy filed a Petition for Injunction and Prohibition in the Regional Trial Court (RTC) of Quezon City, Branch 91, seeking to enjoin enforcement of RMO No. 20‑2013 and RMC No. 52‑2013 insofar as they applied to non‑stock, non‑profit educational institutions. The RTC granted a preliminary injunction on June 26, 2014 and, after motions, issued a Resolution on October 10, 2014 declaring RMO No. 20‑2013 unconstitutional and RMC No. 52‑2013 illegal as applied to such institutions.
Respondents — Commissioner Jacinto‑Henares, Detablan, Florendo, and the Republic of the Philippines (through the Office of the Solicitor General) — sought reconsideration and appealed. The Court of Appeals (CA), in an August 31, 2016 decision, granted the appeal, set aside the RTC’s Order and Resolution, and dismissed the petition. The CA reasoned preliminarily that the Commissioner acted pursuant to her rule‑making power and that injunction/prohibition were inappropriate remedies against quasi‑legislative acts; it also relied on procedural rules (Rules 58 and 65) to dismiss the remedies sought. The CA denied reconsideration by Resolution dated March 1, 2017.
St. Mary’s Academy petitioned the Supreme Court by Rule 45, contending (inter alia) that the CA improperly resolved purely legal questions on procedural grounds, that the expanded power of judicial review could sustain an action for prohi...(Pro-only)
Issues:
- Did the Regional Trial Court have jurisdiction to entertain and decide the petition challenging the constitutionality and validity of RMO No. 20‑2013 and RMC No. 52‑2013?
- If the RTC lacked jurisdiction, was the Court of Appeals correct in setting aside the RTC's orders and in addressing the propriety of injunction and prohibition against the c...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)