Case Summary (G.R. No. L-10935)

Jurisdiction of the Court of Tax Appeals

The Court of Tax Appeals possesses exclusive appellate jurisdiction over disputes concerning tax assessments. According to Section 7 of Republic Act No. 1125, this court is designated to review decisions made by the Collector of Internal Revenue regarding disputed assessments and other matters related to the National Internal Revenue Code. Consequently, any taxpayer who disagrees with a tax assessment must appeal to the Court of Tax Appeals rather than the Court of First Instance.

• The Court of Tax Appeals has exclusive appellate jurisdiction.
• Jurisdiction covers disputed assessments and related matters.
• Taxpayers must appeal to the Court of Tax Appeals for disagreements.

Background of the Case

On May 10, 1956, Hao Giok San filed a complaint in the Court of First Instance of Cebu against the Collector of Internal Revenue, Silverio Blaquera, seeking to prevent the collection of alleged deficiency taxes amounting to P3,625. The respondent Judge issued a preliminary injunction against the petitioner, which prompted the latter to file a motion to dismiss the case based on jurisdictional grounds. The motion was denied, leading to the present petition for a writ of prohibition.

• Hao Giok San filed a complaint against the Collector of Internal Revenue.
• The complaint sought to prevent tax collection and enforce a preliminary injunction.
• The petitioner’s motion to dismiss was denied, prompting further legal action.

Disputed Tax Assessment

The dispute arose from a communication sent by the Deputy Collector of Internal Revenue, which indicated that Hao Giok San had underpaid his percentage taxes. The total amount due, including surcharges, was P3,625. Hao Giok San contested this claim, asserting that he had paid all taxes owed. This disagreement over the tax assessment led to the initiation of Civil Case No. R-4514.

• The Deputy Collector claimed a tax deficiency of P3,625.
• Hao Giok San denied any outstanding tax liability.
• The disagreement resulted in the filing of a civil case.

Legal Question of Jurisdiction

The central legal question is whether the Court of First Instance of Cebu has jurisdiction to hear the civil case concerning the collection of deficiency taxes. The petitioner argues that the matter should be appealed to the Court of Tax Appeals, as the case involves a review of the Collector's actions regarding tax assessments and potential levies on property.

• The main question is about the jurisdiction of the Court of First Instance.
• The petitioner contends that the case should be appealed to the Court of Tax Appeals.
• The case involves a...continue reading

Case Syllabus (G.R. No. L-10935)

Case Overview

• The case was filed under G.R. No. L-10935, with a decision dated April 28, 1958, reported in 103 Phil. 511.
• Silverio Blaquera, as the Collector of Internal Revenue, is the petitioner, while Hon. Judge Jose S. Rodriguez and Hao Giok San are the respondents.
• The primary legal issue revolves around the jurisdiction of the Court of First Instance of Cebu to hear a case concerning the collection of deficiency taxes.

Background of the Case

• On May 10, 1956, Hao Giok San filed a complaint in the Court of First Instance of Cebu against the petitioner for an injunction to stop the collection of alleged deficiency taxes amounting to P3,625.
• The complaint aimed to prevent Blaquera from levying any of Hao Giok San's properties and sought a permanent injunction after a trial.
• On the same date, the court issued a writ of preliminary injunction after Hao Giok San posted a bond for the said amount.

Procedural History

• Following the issuance of the preliminary injunction, Blaquera filed a motion to dismiss the complaint, claiming lack of jurisdiction by the Court of First Instance.
• The motion was denied by Judge Rodriguez, and subsequent petitions for reconsideration were also dismissed.
• Subsequently, Blaquera filed a petition for prohibition to ...continue reading