Case Digest (G.R. No. 115455) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 5, 1994, President Ramos signed Republic Act No. 7716 (the Expanded Value‐Added Tax Law), amending sections of the National Internal Revenue Code to broaden the VAT base. It was published May 12, took effect May 28, and was immediately challenged in multiple petitions for certiorari and prohibition before the Supreme Court en banc. Petitioners included Senator Arturo M. Tolentino; Senator Juan T. David; Senator Raul S. Roco with the Integrated Bar of the Philippines; the Philippine Press Institute and other media groups; the Chamber of Real Estate and Builders Associations (CREBA); the NGO Kilusang Bayan; Philippine Airlines (PAL); Cooperative Union of the Philippines; and the Philippine Educational Publishers Association. They sought to stop implementation of the law, claiming procedural and substantive constitutional defects. The Court granted a temporary restraining order on June 30, 1994 and resolved the consolidated cases on August 25, 1994.Issues:
- Did Republic
Case Digest (G.R. No. 115455) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Legislative Background
- Executive Order No. 273 (July 25, 1987) introduced a multi‐stage value‐added tax (VAT) on goods and services, replacing the turnover tax and single‐stage VAT of the 1939 National Internal Revenue Code.
- Efforts to amend and expand the VAT base began as early as July 1992 with ten House bills (HB Nos. 253, 771, 2450, 7033, 8086, 9030, 9210, 9297, 10012, 10100) and two Senate measures (P.S. Res. No. 734 filed September 10, 1992; SB No. 1129 filed March 1, 1993).
- Passage of Republic Act No. 7716
- H.B. No. 11197, consolidating the ten House VAT bills, was approved by the House on third reading on November 17, 1993, and transmitted to the Senate on November 18, 1993.
- The Senate Committee on Ways and Means submitted Committee Report No. 349 (February 7, 1994) recommending approval of SB No. 1630 “in substitution of SB No. 1129, taking into consideration P.S. Res. No. 734 and H.B. No. 11197.”
- S.B. No. 1630 was then approved on second and third readings by the Senate on March 24, 1994, after President Ramos certified its urgency on March 22, 1994.
- A bicameral conference committee met in April 1994 to reconcile H.B. No. 11197 and SB No. 1630; its report was approved by the House on April 27 and by the Senate on May 2.
- President Ramos signed the enrolled bill into law as R.A. No. 7716 on May 5, 1994; publication followed on May 12, 1994, and the law took effect on May 28, 1994.
- Petitions and Claims
- Nine separate petitions for certiorari, prohibition, mandamus and injunction challenged R.A. No. 7716’s procedural validity (origination, readings, bicameral process) and substantive provisions (alleged discrimination, impairment of contracts, press and religious freedom violations).
- Petitioners include Senator Tolentino, Philippine Press Institute, Philippine Bible Society, Philippine Airlines, CREBA, Kilosbayan and others.
Issues:
- Procedural Validity
- Whether R.A. No. 7716 violates Article VI, Section 24 (exclusive origination of revenue bills in the House).
- Whether it violates Article VI, Section 26(2) (three readings on separate days, printed copies distributed).
- Whether the bicameral conference committee exceeded its authority by inserting new provisions.
- Substantive Validity
- Whether the law abridges freedom of speech, expression or of the press (Art. III, Sec. 4).
- Whether it violates free exercise of religion (Art. III, Sec. 5).
- Whether it impairs contractual and vested rights (Art. III, Sec. 10; Art. VI, Sec. 28).
- Whether it denies equal protection or due process (Art. III, Sec. 1).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)