Title
Compania General de Tabacos de Felipinas vs. City of Manila
Case
G.R. No. L-16619
Decision Date
Jun 29, 1963
Tabacalera sought a refund of P15,208.00 for overpaid sales taxes on liquor, claiming double taxation. The Supreme Court ruled that license fees (regulatory) and sales taxes (revenue) serve distinct purposes, dismissing the refund claim.

Case Summary (G.R. No. L-16619)

Facts

  • Tabacalera, licensed under Ordinance No. 3358 as a first-class wholesale and retail dealer of intoxicating liquors, also operated as a wholesale and retail dealer of general merchandise.
  • In its sworn quarterly declarations from Q3 1954 to Q2 1957 Tabacalera included liquor sales among its general merchandise sales and paid corresponding wholesale and retail sales taxes imposed by Ordinances Nos. 3634, 3301, and 3816, resulting in the payment at issue (P15,208.00 as the tax portion attributable to liquor sales).
  • Ordinances Nos. 3634 and 3816 amended prior ordinances and, via administrative regulation (Exhibit A), treated “general merchandise” to include items enumerated in certain sections of the National Internal Revenue Code, which specifically included liquor.
  • In 1954 the City Treasurer communicated, by letter addressed to a private accounting firm, his view that liquor dealers who pay the annual license fee under Ordinance No. 3358 were not also subject to the wholesalers’ and retailers’ taxes under the other ordinances. After learning of that opinion Tabacalera ceased including liquor sales in its later quarterly declarations. On December 3, 1957 Tabacalera formally demanded refund of the taxes previously paid; the demand was denied and Tabacalera instituted the present suit.

Contentions of the Parties

  • Tabacalera’s primary contention: Because it already paid the annual license fees prescribed by Ordinance No. 3358 for the privilege of selling liquor, it should not also be subject to the municipal wholesalers’ and retailers’ sales taxes on the same liquor sales; the sales taxes it paid were an overpayment made by mistake and are therefore refundable.
  • City’s defenses: (a) Ordinance No. 3358 license fees and the sales taxes are separate obligations and Tabacalera properly paid both; (b) if any overpayment occurred, it was paid voluntarily without protest and resulted from a mistake of law and the plaintiff’s neglect; (c) the tax amounts were passed on to consumers via elevated selling prices; and (d) the sums paid had already been expended for public improvements and services from which Tabacalera benefited.

Legal Principles Applied

  • Distinction between license fees and taxes: The Court reiterated the legal difference — license fees are exactions imposed in the exercise of the police power for regulation, whereas taxes are imposed under the taxing power primarily to raise revenue. Although the terms are sometimes used loosely, the legal distinction is significant for determining permissibility of multiple impositions.
  • Municipal authority: Under the charter powers vested in the Municipal Board of Manila (as expressed in Section 18 of Republic Act No. 409, cited in the opinion), the Board may fix license fees for regulated callings (e.g., sale of intoxicating liquors) and separately may impose taxes on dealers for purposes of revenue.
  • Double taxation doctrine: The Court recognized that the imposition of both a regulatory license fee and a separate tax on the sale of the same article or business is not per se a violation of the rule against double taxation; authorities and texts (e.g., Bentley Gray Dry Goods Co. v. City of Tampa; McQuillin) support the position that both may lawfully be imposed where one is regulatory and the other is a revenue measure.
  • Government non‑liability for legal errors of officers: The Court held that erroneous legal advice or opinions by government officers (here, the City Treasurer’s view communicated to an accounting firm) do not bind the government and cannot estop the City from enforcing its ordinances.

Application to the Facts and Court’s Analysis

  • Characterization of the two exactions: The Court characterized Ordinance No. 3358 as a license scheme enacted pursuant to the Municipal Board’s power to regulate the sale of intoxicating liquors — a regulatory measure rooted in police power addressing health and morals. Conversely, Ordinances Nos. 3634, 3301, and 3816 were characterized as revenue measures imposing wholesale and retail taxes on sales of general merchandise (and, under their terms and administrative interpretation, inclusive of liquor).
  • Effect on Tabacalera’s claim: Because the license fee and the sales taxes served different governmental ends — regulation versus revenue — their concurrent application to the sale of liquor did not constitute unlawful double taxation. The Court therefore concluded that the tax payments by Tabacalera were not an overpayment for which refund was warranted on the basis argued.
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