GR 47917; (October, 1942)

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📖 Full Court Text ⚡ Case Digest 🕵️ Case Critique

⚖️ CASE INTELLIGENCE

📌 CORE DOCTRINE

“Taxes are due according to the law in force at the time of levy, and repealing statutes generally apply prospectively unless otherwise specified.”

💡 PLAIN ENGLISH SUMMARY

The court ruled that the mining association still had to pay a tax because the law requiring it was in effect when the tax was due, even though it was later repealed. This ensures fairness by holding people accountable to the rules that existed at the time, preventing them from avoiding taxes just because laws change later.

📜 LEGAL MAXIM

Lex prospicit, non respicit | Nova constitutio futuris formam imponere debet, non praeteritis

VERIFIED AI SNAPSHOT FOR ARMZTRONG.ORG

EN BANC

G.R. No. 47917 ; October 30, 1942

PANAGAN MINING ASSOCIATION, plaintiff-appellant,

vs.
ALFREDO L. YATCO, Collector of Internal Revenue, defendant-appellee.

Agustin Alvarez Salazar for appellant.
Office of the Solicitor-General Ozaeta and Solicitor Kapunan, Jr. for appellee.

BOCOBO, J.:

1. TAXATION; EFFECT OF REPEAL OF LAW IMPOSING TAX. — Act No 4243 imposing the tax in question was repealed on November 7, 1936, by Commonwealth Act No. 137 , and this tax was paid on December 29, 1936. It is, however, well-settled principle of taxation that taxes are due according to the law in force when they were levied, and that the rule favoring a prospective construction is appealable to statutes repealing tax lay.

2. ID; EFFECT OF NON-PAYMENT OF TAX IN QUESTION. — The tax under Act No. 4243 is not a kind of privilege tax the non-payment of which merely causes the loss of the privilege of obtaining the patent to mining claims. A reading of Act No. 4243 shows that this tax must necessarily be paid by every locator of a mining claim who does not do any assessment work in any given year, regardless of whether or not he subsequently continues fulfilling all the requirements for securing a patent. This is to insure good faith on the part of locators.

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