Case Digest (G.R. No. 104037) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the consolidated cases of Reynaldo v. Umali (G.R. No. 104037) and Gorospe et al. v. Commissioner of Internal Revenue (G.R. No. 104069), individual Filipino taxpayers led respectively by Reynaldo Umali of Gitnang Bayan, Bongabong, Oriental Mindoro, and by Rene B. Gorospe, Leighton R. Siazon, Manuel M. Sunga, Paul D. Ungos, Bienvenido T. Jamoralin Jr., Jose D. Flores Jr., Evelyn G. Villegas, Domingo T. Ligot, Henry E. Laron, Pastor M. Dalmacion Jr., and Julius Norman C. Cerrada, petitioned for mandamus and prohibition against Hon. Jesus P. Estanislao, Secretary of Finance, and Hon. Jose U. Ong, Commissioner of Internal Revenue. Congress had enacted Republic Act No. 7167 on December 19, 1991, adjusting the basic personal exemptions (from ₱6,000–₱12,000 to ₱9,000–₱18,000) and additional exemptions (from ₱3,000 to ₱5,000 per dependent) “to the poverty threshold level,” and the Act was published in the Malaya on January 14, 1992. Respondents issued Revenue Regulations No. 1-92 on D Case Digest (G.R. No. 104037) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Republic Act No. 7167
- Enacted “AN ACT ADJUSTING THE BASIC PERSONAL AND ADDITIONAL EXEMPTIONS ALLOWABLE TO INDIVIDUALS FOR INCOME TAX PURPOSES TO THE POVERTY THRESHOLD LEVEL,” amending Section 29(L)(1) and (2)(A) of the NIRC.
- Key provisions:
- Personal exemptions – P9,000 for single or legally separated, P12,000 for head of family, P18,000 for married individuals (P9,000 each if spouses file separately).
- Additional exemptions – P5,000 per dependent (max four), P1,000 per child dependent prior to 1 January 1980, claimed by one spouse if filing separately.
- Approved by the President on 19 December 1991; published in Malaya on 14 January 1992.
- Revenue Regulations No. 1-92
- Promulgated by the Secretary of Finance and the Commissioner of Internal Revenue (dated 26 December 1992).
- Amended the withholding tax tables and Section 8 of RR No. 6-82 (as amended by RR No. 1-86), providing that the increased exemptions apply only to compensation paid on or after 1 January 1992.
- Stated effectivity: compensation income from 1 January 1992.
- Petitions and Proceedings
- G.R. No. 104037 – Petitioner Reynaldo Umali filed for mandamus (27 February 1992) to compel implementation of RA 7167 for income earned/received on or after 1 January 1991 (taxable year 1991).
- G.R. No. 104069 – Petitioners Gorospe et al. filed for mandamus and prohibition (28 February 1992) to implement RA 7167 for 1991 income and enjoin RR 1-92.
- Cases consolidated on 10 March 1992; respondents commented within the prescribed period.
- Precedent on Effectivity of Laws
- Civil Code, Article 2 – Laws take effect 15 days after publication unless otherwise provided; publication is indispensable.
- Tanada v. Tuvera (146 SCRA 446) and Caltex (G.R. No. 97282, 26 June 1991) – A statute with no specific effectivity date takes effect 15 days after publication.
Issues:
- When did RA 7167 take effect: upon presidential approval (19 December 1991) or 15 days after publication (30 January 1992)?
- If effectivity is 30 January 1992, does RA 7167 nonetheless apply to compensation income earned or received during calendar year 1991?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)