Facts:

• Dr. Felisa L. Vda. de San Agustin is the petitioner, substituting for Jose Y. Feria, executor of the estate of the late Jose San Agustin.
• Jose San Agustin, a lawyer, died on June 27, 1990, leaving a holographic will dated April 21, 1980, bequeathing his estate to his wife, Dra. Felisa L. San Agustin.
• The will appointed retired Justice Jose Y. Feria as executor.
• Probate proceedings began on August 22, 1990, in the RTC of Makati, Branch 139, under Special Proceedings No. M-2554.
• Notice of death was sent to the Commissioner of Internal Revenue (CIR) on August 30, 1990.
• An estate tax return was filed on September 3, 1990, reporting a tax due of P1,676,432.00, with a request for a two-year extension for payment.
• The BIR granted a six-month extension, subject to penalties and interest.
• The RTC allowed the will on October 11, 1990, and authorized the executor to withdraw funds for tax payment on March 5, 1991.
• The estate tax was paid on March 8, 1991, within the extension period.
• On September 23, 1991, Felisa San Agustin received a Pre-Assessment Notice from the BIR for a deficiency estate tax of P538,509.50, totaling P976,540.00 with penalties and interest.
• The executor was ready to pay the basic deficiency tax but requested a waiver of additional charges due to a zonal valuation difference.
• An Assessment Notice was issued on October 4, 1991, demanding payment within thirty days.
• The estate paid the additional charges under protest on January 25, 1993, and filed a Petition for Review with the Court of Tax Appeals (CTA) on February 18, 1993.
• The CTA modified the CIR's assessment, ordering a refund of P423,577.64.
• The CIR appealed to the Court of Appeals, which ruled in favor of the CIR, stating the CTA lacked jurisdiction, leading to the current petition for review.

Issue:

• (Unlock)

Ruling:

• The Supreme Court partly granted the petition, affirming the jurisdiction of the Court of Tax Appeals over the case.
• The deficiency assessment for surcharge, interest, and penalties was modified to a total of P148,090.00, which includes a surcharge of P134,627.37 and interest of ...(Unlock)

Ratio:

• The Supreme Court held that the Court of Tax Appeals had jurisdiction, stating that a written claim for refund is not a prerequisite for filing a petition for review.
• The Court referenced previous cases allowing taxpayers to appeal disputed assessments w...continue reading