Case Digest (G.R. No. L-11940) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Taihei Alltech Construction (Phil.) Inc. (Taihei), a domestic corporation engaged in constructing industrial plants and registered with the Bureau of Internal Revenue (BIR) under Certificate of Registration dated June 22, 1994, filed administrative claims for refund of unutilized excess input Value Added Tax (VAT) for the 3rd and 4th quarters of 2011 totaling P19,345,434.54. These claims were filed on September 30, 2013, and December 23, 2013, respectively, within the two-year prescriptive period under Section 112(A) of the National Internal Revenue Code (NIRC), as amended. The Commissioner of Internal Revenue (CIR) issued Revenue Memorandum Circular No. 54-2014 (RMC 54-2014) on June 11, 2014, enforcing stricter requirements for filing VAT refunds, effectively deeming unacted claims as denied after 120 days. Taihei contended that their claims were deemed denied by retroactive application of RMC 54-2014. Subsequently, the CIR issued Revenue Regulations No. 1-2017 (RR 1-2017) to c Case Digest (G.R. No. L-11940) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties Involved
- Petitioner: Taihei Alltech Construction (Phil.) Inc. (Taihei), a domestic corporation engaged in industrial plant construction, VAT-registered since June 22, 1994.
- Respondent: Commissioner of Internal Revenue (CIR).
- Subject Matter
- Taihei filed administrative claims for refund representing unutilized excess input VAT for the 3rd quarter (P6,649,651.47) and 4th quarter (P12,695,783.07) of calendar year 2011.
- Claims were filed on September 30, 2013, and December 23, 2013 respectively, purportedly with all supporting documents.
- Relevant Regulations and Circulars
- Section 112(A) & (C) of the National Internal Revenue Code (NIRC) as amended – provides a two-year prescriptive period to file administrative claims for refund and a 120-day period for the CIR to act on complete claims.
- Revenue Memorandum Circular No. 54-2014 (RMC 54-2014) – issued June 11, 2014, mandates filing complete supporting documents with initial claim and states failure to act by CIR within 120 days is deemed denial.
- Revenue Regulations No. 1-2017 (RR 1-2017) – issued January 3, 2017, clarifies claims filed prior to RMC 54-2014 continue to be processed administratively; alleged to "revive" claims deemed denied under RMC 54-2014 by Taihei.
- BIR Ruling No. DA-489-03 (2003-2010) – previously allowed premature judicial claims before lapse of 120-day period.
- Procedural Posture
- CIR initially issued no decision within 120 days after claims, deeming the claims denied by operation of law.
- CIR later issued denial letter on February 6, 2019, citing violations such as improper invoicing and lack of proof for input VAT claims.
- Taihei filed Petition for Review with Court of Tax Appeals (CTA) on July 10, 2019, exceeding the 30-day period after deemed denial or actual denial.
- CTA Second Division dismissed Taihei’s petition on the ground of lack of jurisdiction due to late filing.
- CTA En Banc affirmed dismissal and denial of motion for reconsideration.
- Taihei elevated case to the Supreme Court alleging retroactive application of RMC 54-2014, revival of claim by RR 1-2017, and jurisdiction over its petition.
Issues:
- Whether Taihei’s judicial claims for refund were filed beyond the mandatory 120+30-day period under Section 112(C), NIRC.
- Whether RMC 54-2014 was retroactively applied to invalidate Taihei’s 120-day period to file a judicial claim.
- Whether RR 1-2017 effectively revived Taihei’s lapsed claims for refund.
- Whether RMC 54-2014 and RR 1-2017 created an exception to the mandatory and jurisdictional 120+30-day period for judicial claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)