Title
Commissioner of Internal Revenue vs. Wyeth Suaco Laboratories, Inc.
Case
G.R. No. 76281
Decision Date
Sep 30, 1991
Wyeth Suaco contested BIR's tax assessments, arguing prescription and liability issues. SC ruled BIR's collection period was interrupted by protests; Wyeth liable for withholding tax on accrued royalties/dividends and deficiency sales tax.
A

Case Summary (G.R. No. 76281)

Factual Background

Wyeth Suaco Laboratories, Inc. was a domestic corporation engaged in manufacture and sale of pharmaceutical and nutritional products with a fiscal year ending October 31. Revenue Examiner Dante Kabigting, acting under Letter of Authority No. 52415, examined Wyeth Suaco's books and on October 15, 1974 reported that Wyeth Suaco had accrued royalties payable to foreign licensors, remuneration for technical services to a foreign affiliate, and declared cash dividends on September 27, 1973 paid October 31, 1973. The report concluded that Wyeth Suaco had failed to remit withholding tax at source for the fourth quarter of 1973 on accrued royalties, technical services and dividends, producing an asserted deficiency withholding tax of P3,178,994.15. The examiner also found underpaid advance sales tax for various periods and an alleged short payment on an import, yielding a deficiency sales tax of P60,855.21 plus a compromise penalty of P300, totaling P61,155.21.

Administrative Assessment and Protest

The Bureau of Internal Revenue issued assessments by notices dated December 16 and 17, 1974, received December 19, 1974. Wyeth Suaco, through tax consultant Sycip, Gorres, Velayo & Co. (SGV & Co.), sent protest letters dated January 17 and February 8, 1975 requesting cancellation or withdrawal of the assessments for lack of factual and legal basis. Wyeth Suaco contended that withholding on royalties and dividends became payable only upon actual remittance, and that Central Bank restrictions (CB Circular No. 289 and implementing memorandum) prevented full remittance. Wyeth Suaco also disputed the revenue examiner's landed cost computations supporting the sales tax assessment, while admitting liability for a P1,000 short payment on a specific import.

Administrative Review and Final Assessment

The Bureau of Internal Revenue’s Manufacturing Audit Division undertook review and reinvestigation in response to Wyeth Suaco’s protests. The Bureau offered compromise under LOI 308 on September 12, 1975; Wyeth Suaco accepted a 10% compromise only on basic sales tax. After review, Acting Commissioner Ruben B. Ancheta rendered a final assessment dated December 10, 1979, reducing the withholding tax assessment to P1,973,112.86 while maintaining the sales tax deficiency at P61,155.21. The final assessment was received by Wyeth Suaco on January 2, 1980.

Procedural History

Wyeth Suaco filed a petition for review with the Court of Tax Appeals on January 18, 1980 praying for enjoinment of collection on the ground of prescription and for annulment of the assessments. The Commissioner issued warrants of distraint and levy on February 7, 1980, served March 12, 1980. The Court of Tax Appeals enjoined collection by resolution of May 22, 1980. On August 29, 1986 the Court of Tax Appeals rendered a decision enjoining the Commissioner from collecting the deficiency withholding tax for the fourth quarter of 1973 and the deficiency sales tax, holding that the right to collect had prescribed under Section 319(c) of the Tax Code of 1977. The Commissioner sought review by certiorari in the Supreme Court.

Issue Presented

The dispositive issue presented to the Supreme Court was whether the Commissioner’s right to collect the assessed deficiency withholding tax and deficiency sales tax from Wyeth Suaco Laboratories, Inc. had prescribed under Section 319(c) of the National Internal Revenue Code of 1977, or whether the prescriptive period had been interrupted by Wyeth Suaco’s protest and request for reinvestigation or reconsideration.

Petitioner's Argument on Prescription

The Commissioner conceded that more than five years had elapsed between the original assessments received December 19, 1974 and the service of distraint and levy on March 12, 1980, but argued that the running of the five-year prescriptive period was interrupted when Wyeth Suaco, through SGV & Co., protested the assessments by letters of January 17 and February 8, 1975 and thus effectively requested reinvestigation or reconsideration. The Commissioner relied on the settled rule that a taxpayer’s request for review or reconsideration interrupts prescription, citing prior decisions such as Commissioner of Internal Revenue v. Capitol Subdivision, Inc. and others.

Respondent's Position on Prescription

Wyeth Suaco Laboratories, Inc. contended that its protest letters sought only cancellation or withdrawal of the assessments for lack of legal and factual basis and did not request reinvestigation or reconsideration; accordingly, Wyeth Suaco argued that the five-year period for collection under Section 319(c) was not suspended or interrupted and that the Commissioner’s collection remedy had prescribed.

Court's Analysis on Interruption of Prescription

The Court examined the record and found evidence that Wyeth Suaco did seek reconsideration. It relied on a letter of James A. Gump, President and General Manager of Wyeth Suaco, dated April 28, 1975 expressly stating that the company was "seeking reconsideration" of the alleged deficiencies as a follow-up to earlier protests. The Court further observed that Wyeth Suaco’s Finance Manager acknowledged on July 1, 1975 that the matter was "undergoing review and consideration" by the Manufacturing Audit Division, thereby demonstrating that the Bureau had reinvestigated the assessments in response to Wyeth Suaco’s communications. The Court held that although the initial protest letters did not use the specific words "reinvestigation" or "reconsideration," they must be treated as requests for reconsideration because they induced the Bureau to undertake review. Consequently, the running of the five-year prescriptive period was interrupted upon receipt of the taxpayer’s protest and recommenced only upon service of the final assessment.

Final Assessment and Restart of Prescriptive Period

The Court concluded that the statutory five-year period began to run anew upon Wyeth Suaco’s receipt of the Bureau’s final assessment on January 2, 1980. Because the warrants of distraint and levy were served on Wyeth Suaco on March 12, 1980, the Commissioner’s collection proceedings were instituted within the five-year period following the final assessment. The Court therefore found no prescription bar to collection.

Merits: Withholding Tax at Source

On the substantive tax issues, the Court addressed Wyeth Suaco’s contention that withholding taxes on royalties and dividends become payable only upon actual remittance abroad and that the Bureau could not require remittance where Central

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