Case Summary (G.R. No. 192536)
Factual Background
Alcantara was the owner of a 301 square meter parcel of land in Buhangin, Davao City, covered by Transfer Certificate of Title (TCT) No. T-113015. The BIR conducted an assessment regarding his income taxes for the years 1982 and 1983. Despite attempts by the BIR to contact Alcantara regarding alleged deficiencies totaling P32,076.52, he did not respond, leading to the issuance of a Warrant of Distraint and Levy in 1991, followed by a Notice of Seizure of Real Property and a Declaration of Forfeiture. The property was sold at a public auction to Maximo Lagahit in 1995. Alcantara, upon discovering the forfeiture and sale, instituted a legal action seeking the reconveyance of his property.
Proceedings in Lower Courts
The Regional Trial Court (RTC) dismissed Alcantara's complaint for lack of jurisdiction, reasoning that he failed to exhaust available administrative remedies with the BIR prior to filing a lawsuit. The Court of Appeals (CA) affirmed this ruling, stating that Alcantara should have sought administrative relief by filing a protest against the assessment and a claim for refund before approaching the courts.
Jurisdictional Issues
Central to the dispute is whether the RTC correctly determined it lacked jurisdiction. Alcantara argued that his case involved a declaration of nullity of the TCTs and, thus, fell within the RTC's jurisdiction under Batas Pambansa Bilang 129. However, the CA and the Supreme Court maintained he was effectively contesting the BIR's tax assessments, which are matters within the exclusive jurisdiction of the Court of Tax Appeals (CTA) as established under Republic Act No. 1125.
Rulings and Legal Basis
The Supreme Court upheld the decisions of the lower courts, confirming that Alcantara's failure to take necessary administrative steps, as outlined in Sections 229 and 230 of the National Internal Revenue Code, resulted in the finality of the tax assessments. The Court noted that these legislative provisions require a taxpayer to protest assessments and seek refunds p
...continue readingCase Syllabus (G.R. No. 192536)
Background of the Case
- The case revolves around Demetrio R. Alcantara (the petitioner) who owned a parcel of land located in Buhangin, Davao City, identified by Transfer Certificate of Title (TCT) No. T-113015.
- The respondents included the Republic of the Philippines through the Bureau of Internal Revenue (BIR) and various officials associated with the BIR.
- The petitioner filed income tax returns for the years 1982 and 1983, during which a tax assessment claimed he owed a total of P32,076.52, which included deficiency income tax, surcharges, interests, and penalties.
Procedural History
- The BIR issued demand letters to Alcantara, which went unanswered.
- A Warrant of Distraint and/or Levy was issued against Alcantara's property on August 12, 1991, and subsequently, a Notice of Seizure was served, followed by a Declaration of Forfeiture on May 4, 1992, stating that the property was forfeited to the government due to non-payment of taxes.
- The Register of Deeds of Davao City subsequently canceled Alcantara's title and issued a new title in the name of the Republic of the Philippines.
- A resale auction was conducted, culminating in the sale of the property to Maximo Lagahit, who received a new TCT.
Allegations of the Petitioner
- Alcantara claimed he was unaware of the assessments and forfeiture due to not receiving valid notices, as he had emigrated to the United States in August 1985.
- He alleged that the BIR f