LCA Lines | Volume IV, Issue No. 6

8/12/2019 LCA Lines | Volume IV, Issue No. 6

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LCA LINESServing your purpose, realizing your dreams..

Volume IV Issue No. 6 J U N E 2 0 1 2

BIR ISSUANCES

I n s i d e t h i s

I s s u e:

BIR Issuances

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Jurisprudence

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JLs Corner

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REVENUE REGULATIONS NO. 9-2012 issued on June 1, 2012 im-plements Sections 24(D)(1), 27(D)(5), 57, 106 and 196 of the Nation-al Internal Revenue Code (NIRC)of 1997 relative to the non-redemption of properties sold dur-ing involuntary sales.

In case of non-redemption of prop-erties sold during involuntary sales,regardless of the type of proceed-ings and personality of mortga-gees/selling persons or entities,the Capital Gains Tax (CGT), if theproperty is a capital asset; or theCreditable Withholding Tax (CWT),if the property is an ordinary asset;

the Value-Added Tax (VAT) and

the Documentary Stamp Tax(DST) shall become due.

The buyer of the subject property,who is deemed to have withheldthe CGT or CWT due from thesale, shall then file the CGT returnand remit the said tax to the BIRwithin 30 days from expiration ofthe applicable statutory redemption

period, or file the CWT return andremit the said tax to the BIR within10 days following the end of themonth after expiration of the appli-cable statutory redemption period,provided that, for taxes withheld inDecember, the CWT return shallbe filed and the taxes remitted tothe BIR on or before January 15 ofthe following year.

If the property sold through invol-untary sale is under the circum-stances which warrant the impo-sition of VAT, the said tax must

be paid to the BIR by the VAT-registered owner/mortgagor on orbefore the 20th day or 25th day,whichever is applicable, of themonth following the month when

the right of redemption pre-scribes.

The DST return shall be filed andthe said tax paid to the BIR within 5days after the close of the monthafter the lapse of the applicablestatutory redemption period. TheCGT/CWT/VAT and DST shall bebased on whichever is higher of theconsideration (bid price of the high-

er bidder) or the fair market value orthe zonal value as determined inaccordance with Section 6(E) of theTax Code.

REVENUE REGULATIONS NO. 10-2012 issued on June 1, 2012 de-fines the requirements for joint ven-tures or consortiums formed for thepurpose of undertaking constructionprojects andprescribes the mandatory enroll-

ment of local contractors in theElectronic Filing and Payment Sys-tem (eFPS).

A joint venture or consortiumformed for the purpose of undertak-ing construction projects, which isnot considered as corporation underSection 22 of the National InternalRevenue Code (NIRC), of 1997 asamended, should be:

a. for the undertaking of a con-struction project;

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LCA LINESServing your purpose, realizing your dreams..

Volume IV Issue No. 6 J U N E 2 0 1 2

BIR ISSUANCES

I n s i d e t h i s

I s s u e:

BIR Issuances

1

JLs Corner

11

b. should involve joining or pooling ofresources by licensed local con-tracts; that is, licensed as generalcontractor by the Philippine Contrac-

tors Accreditation Board (PCAB) ofthe Department of Trade and Indus-try (DTI);

c. the local contractors are engagedin construction business; and

d. the Joint Venture itself must like-wise be duly licensed as such by thePCAB of the DTI.

Joint ventures involving foreign con-tractors may also be treated as anon-taxable corporation only if themember foreign contractor is cov-ered by a special license as contrac-tor by the PCAB of the DTI, and theconstruction project is certified bythe appropriate Tendering Agency(government office) that the projectis a foreign financed/internationally-funded project and that international

bidding is allowed under the BilateralAgreement entered into by and be-tween the Philippine Governmentand the foreign/international financ-ing institution pursuant to the imple-menting rules and regulations of Re-public Act No. 4566, otherwiseknown as Contractors License Law.

Absent any one the aforesaid re-quirements, the joint venture or

consortium formed for the purposeof undertaking construction pro-jects shall be considered as taxa-ble corporations. In addition, the

tax-exempt joint venture or consor-tium shall not include those whoare mere suppliers of goods, ser-vices or capital to a constructionproject. The members to a Joint

Venture not taxable as corporationshall each be responsible in report-ing and paying appropriate IncomeTaxes on their respective share tothe joint ventures profit.

All licensed local contractors arerequired to enroll to the BIRseFPS at the Revenue District Of-fice where they are registered astaxpayers.

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JURISPRUDENCEG.R. No. 152662 June 13, 2012

PEOPLE OF THE PHILIPPINES,

Petitioner,vs.

MA. THERESA PANGILINAN,RespondentSECOND DIVISION

FACTS:

On 16 September 1997, Virginia C.Malolos (private complainant) filed an affidavit-complaint for estafa and violation of BatasPambansa (BP) Blg. 22 against Ma. Theresa

Pangilinan (respondent) with the Office of theCity Prosecutor of Quezon City. The complaintalleges that respondent issued nine (9) checkswith an aggregate amount of Nine Million SixHundred Fifty-Eight Thousand Five HundredNinety-Two Pesos (P9,658,592.00) in favor ofprivate complainant which were dishonored up-on presentment for payment.

On 5 December 1997, respondent filed acivil case for accounting, recovery of commer-

cial documents, enforceability and effectivity ofcontract and specific performance against pri-vate complainant.On 2 March 1998, Assistant City ProsecutorRuben Catubay recommended the suspensionof the criminal proceedings pending the out-come of the civil action respondent filedagainst private complainant the same was ap-proved by the City Prosecutor. private com-plainant raised the matter before the Depart-ment of Justice (DOJ).

On 5 January 1999, then Secretary ofJustice Serafin P. Cuevas reversed the resolu-tion of the City Prosecutor of Quezon City andordered the filing of information for violation ofBP Blg. 22 against respondent.

Consequently, two counts for violation of BPBlg. 22, both dated 18 November 1999, werefiled against respondent Ma.Theresa Pangili-nan on 3 February 2000 before the Office of

the Clerk of Court, Metropolitan Trial Court(MeTC), Quezon City. These cases were raf-

fled to MeTC, Branch 31on 7 June 2000.

On 17 June 2000, respondent filed an

"Omnibus Motion to Quash the Informationand to Defer the Issuance of Warrant of Ar-rest" before MeTC, Branch 31, Quezon City.She alleged that her criminal liability has beenextinguished by reason of prescription.

The MeTC ruled that the criminal ac-tions have already prescribed.

On appeal, the RTC reversed the deci-sion of the MeTC ruling that the criminal ac-

tions for violations of BP 22 have not yet pre-scribed when the same was filed with thecourt a quo considering the appropriate com-plaint that started the proceedings havingbeen filed with the Office of the Prosecutor on16 September 1997.

On review, the CA reversed the deci-sion of the RTC stating that the informationsdocketed as Criminal Cases Nos. 89152 and89152(sic) against the petitioner having been

filed with the Metropolitan Trial Court of Que-zon City only on 03 February 2000, the saidcases had therefore, clearly prescribed.Hence this case.

ISSUE:

Whether or not the filing of the affidavit-complaint for estafa and violation of BP Blg.22 against respondent with the Office of theCity Prosecutor of Quezon City on 16 Septem-ber 1997 interrupted the period of prescriptionof such offense.

HELD:

Yes. The Court found that the CA reversivelyerred in ruling that the offense committed byrespondent had already prescribed. Indeed,

Act No. 3326 entitled "An Act to EstablishPrescription for Violations of Special Acts andMunicipal Ordinances and to Provide WhenPrescription Shall Begin," as amended, is thelaw applicable to BP Blg. 22 cases. Apposite-

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JURISPRUDENCEly, the law reads:

SECTION 1. Violations penalized

by special acts shall, unless otherwiseprovided in such acts, prescribe in ac-cordance with the following rules: (a) xxx;(b) after four years for those punished byimprisonment for more than one month,but less than two years; (c) xxx.

SECTION 2. Prescription shallbegin to run from the day of the commis-sion of the violation of the law, and if thesame be not known at the time, from thediscovery thereof and the institution of ju-

dicial proceedings for its investigation andpunishment.The prescription shall be interrupt-

ed when proceedings are institutedagainst the guilty person, and shall beginto run again if the proceedings are dis-missed for reasons not constituting jeop-ardy.

Since BP Blg. 22 is a special lawthat imposes a penalty of imprisonment ofnot less than thirty (30) days but not more

than one year or by a fine for its violation,it therefor prescribes in four (4) years inaccordance with the aforecited law. Therunning of the prescriptive period, howev-er, should be tolled upon the institution ofproceedings against the guilty person.The affidavit-complaints for the violationswere filed against respondent on 16 Sep-tember 1997. The cases reached theMeTC of Quezon City only on 13 Febru-ary 2000 because in the meanwhile, re-spondent filed a civil case for accountingfollowed by a petition before the CityProsecutor for suspension of proceedingson the ground of "prejudicial question".The matter was raised before the Secre-tary of Justice after the City Prosecutorapproved the petition to suspend pro-ceedings. It was only after the Secretaryof Justice so ordered that the informationsfor the violation of BP Blg. 22 were filedwith the MeTC of Quezon City.

Clearly, it was respondents ownmotion for the suspension of the criminalproceedings, which motion she predicated

on her civil case for accounting, thatcaused the filing in court of the 1997 initi-ated proceedings only in 2000.

G.R. No. 174156 June 20, 2012FILCAR TRANSPORT SERVICES,Petitioner,

vs.JOSE A. ESPINAS,Respondent.

FACTS:

On November 22, 1998, at around 6:30p.m., respondent Jose A. Espinas was drivinghis car along Leon Guinto Street in Manila. Uponreaching the intersection of Leon Guinto andPresident Quirino Streets, Espinas stopped hiscar. When the signal light turned green, he pro-ceeded to cross the intersection. He was alreadyin the middle of the intersection when anothercar, traversing President Quirino Street and go-ing to Roxas Boulevard, suddenly hit and

bumped his car. The other car escaped from thescene of the incident, but Espinas was able toget its plate number and later learned that theregistered owner is Filcar.

Espinas sent several letters to Filcar andto its President and General Manager CarmenFlor demanding payment for damages and onMay 31, 2001, Espinas filed a complaint for dam-ages against Filcar and Carmen Flor.

Filcar on the other hand argued that whileit is the registered owner of the car that hit andbumped Espinas car, the car was assigned to itsCorporate Secretary Atty. Candido Flor, the hus-band of Carmen Flor. Filcar further stated thatwhen the incident happened, the car was beingdriven by Atty. Flors personal driver, TimoteoFloresca.

Filcar denied any liability to Espinas andclaimed that the incident was not due to its faultor negligence since Floresca was not its employ-ee but that of Atty. Flor. Filcar and Carmen Flor


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JURISPRUDENCEboth said that they always exercised the due dili-gence required of a good father of a family inleasing or assigning their vehicles to third par-

ties.

ISSUES:

1.Whether or not Filcar, as reg-istered owner of the motor vehi-cle which figured in an accident,may be held liable for the dam-ages caused to Espinas.

2. Whether or not employer-

employee relationship is re-quired in order to hold the reg-istered owner liable for acci-dent, injury, or death caused bythe operation of the vehicle.

HELD:

1. Yes, Filcar may be held liable.

Filcar, as registered owner, is deemedthe employer of the driver, Floresca, and is

thus vicariously liable under Article 2176 inrelation with Article 2180 of the Civil Code.

It is undisputed that Filcar is the regis-tered owner of the motor vehicle which hitand caused damage to Espinas car; and it ison the basis of this fact that the Court heldFilcar primarily and directly liable to Espinasfor damages.

Under Article 2176, in relation with Ar-

ticle 2180, of the Civil Code, an action predi-cated on an employees act or omission maybe instituted against the employer who isheld liable for the negligent act or omissioncommitted by his employee.

Based on the above-cited article(Article 2176), the obligation to indemnifyanother for damage caused by ones act oromission is imposed upon the tortfeasorhimself, i.e., the person who committed the

negligent act or omission. The law, howev-er, provides for exceptions when it makes

certain persons liable for the act or omis-sion of another.

One exception is an employer who

is made vicariously liable for the tort com-mitted by his employee.

Although the employer is not theactual tortfeasor, the law makes him vicari-ously liable on the basis of the civil lawprinciple of pater familias for failure to ex-ercise due care and vigilance over the actsof ones subordinates to prevent damageto another.

2. No, employer-employee relationshipis not required in determining the vi-

carious liability of the registered owner.

In Equitable Leasing Corporation v.Suyom, (437 SCRA 244, 252 (2002))theCourt ruled that in so far as third personsare concerned, the registered owner of themotor vehicle is the employer of the negli-gent driver, and the actual employer isconsidered merely as an agent of suchowner.

Thus, it is clear that for the purposeof holding the registered owner of the mo-tor vehicle primarily and directly liable fordamages under Article 2176, in relationwith Article 2180, of the Civil Code, the ex-istence of an employer-employee relation-ship, as it is understood in labor relationslaw, is not required. It is sufficient to es-tablish that Filcar is the registered own-er of the motor vehicle causing damage

in order that it may be held vicariously lia-ble under Article 2180 of the Civil Code.

Thus, whether there is an employer-employee relationship between the regis-tered owner and the driver is irrelevant indetermining the liability of the registeredowner who the law holds primarily and di-rectly responsible for any accident, injuryor death caused by the operation of thevehicle in the streets and highways.


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JURISPRUDENCEAs explained by this Court in Erezo,

the general public policy involved in motorvehicle registration is the protection of in-

nocent third persons who may have nomeans of identifying public road malefac-tors and, therefore, would find it difficult ifnot impossible to seek redress for dam-ages they may sustain in accidents result-ing in deaths, injuries and other damages;by fixing the person held primarily and di-rectly liable for the damages sustained byvictims of road mishaps, the law ensuresthat relief will always be available to them.

To identify the person primarily anddirectly responsible for the damages wouldalso prevent a situation where a registeredowner of a motor vehicle can easily es-cape liability by passing on the blame toanother who may have no means to an-swer for the damages caused, thereby de-feating the claims of victims of road acci-dents.

These same principles apply by

analogy to the case at bar. Filcar shouldnot be permitted to evade its liability fordamages by conveniently passing on theblame to another party; in this case, itsCorporate Secretary, Atty. Flor and his al-leged driver, Floresca. Following our rea-soning in Equitable, the agreement be-tween Filcar and Atty. Flor to assign themotor vehicle to the latter does not bindEspinas who was not a party to and has noknowledge of the agreement, and whoseonly recourse is to the motor vehicle regis-tration.

Neither can Filcar use the defensesavailable under Article 2180 of the CivilCode -that the employee acts beyond thescope of his assigned task or that it exer-cised the due diligence of a good father ofa family to prevent damage -because themotor vehicle registration law, to a certainextent, modified Article 2180 of the CivilCode by making these defenses unavaila-ble to the registered owner of the motor

vehicle.Thus, for as long as Filcar is theregistered owner of the car involved in thevehicular accident, it could not escape pri-

mary liability for the damages caused toEspinas.

G.R. No. 193676 June 20, 2012COSMOS BOTTLING CORP.,Petitioner,

vs.WILSON FERMIN,Respondent.

x -----------------------xG.R. No. 194303

WILSON B. FERMIN,Petitioner,

vs.

COSMOS BOTTLING CORPORATION and CE-CILIA BAUTISTA,Respondents.

FACTS:

Wilson B. Fermin (Fermin) was a forkliftoperator at Cosmos Bottling Corporation(COSMOS), where he started his employmenton 27 August 1976.On 16 December 2002,he was accused of stealing the cellphone of

his fellow employee, Luis Braga(Braga).Fermin was then given a ShowCause Memorandum, requiring him to explainwhy the cellphone was found inside his lock-er.In compliance therewith, he submitted anaffidavit the following day, explaining that heonly hid the phone as a practical joke and hadevery intention of returning it to Braga.

After conducting an investigation, COS-MOS found Fermin guilty of stealing Bragasphone in violation of company rules and regu-lations.Consequently,the company terminat-ed Fermin from employment after 27 years ofservice,effective on 6 October 2003.

Following the dismissal of Fermin fromemployment, Braga executed an affidavit,which stated the belief that the former hadmerely pulled a prank without any intention ofstealing the cellphone, and withdrew fromCOSMOS his complaint against Fermin.

Meanwhile, Fermin filed a Complaint for


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JURISPRUDENCEIllegal Dismissal,which the Labor Arbiter (LA)dismissed for lack of merit on the ground thatthe act of taking a fellow employees cellphone

amounted to gross misconduct.

Further, theLA likewise took into consideration Ferminsother infractions, namely: (a) committing actsof disrespect to a superior officer, and (b)sleeping on duty and abandonment of duty.

COSMOS, on which the onus of provinglawful cause in sustaining the dismissal of[Fermin] lies, failed to prove that the lattersmisconduct was induced by a perverse andwrongful intent, especially in the light of

Bragas Sinumpaang Salaysay which corrobo-rated [Fermins] claim that [Fermin] was mere-ly playing a prank when he hid Bragas cellularphone. Parenthetically, the labor courts dis-missed Bragas affidavit of desistance as amere afterthought because the same was exe-cuted only after [Fermin] had been terminated.

COSMOS argues, among other things,that: (a) Fermin committed a clear act of badfaith and dishonesty in taking the cellphone of

Braga and denying knowledge thereof; (b) thelatters recantation was a mere afterthought;(c) the lack of material damage or prejudice onthe part of COSMOS does not preclude it fromimposing the penalty of termination; and (d)the previous infractions committed by Ferminstrengthen the decision of COSMOS to dis-miss him from service.

On the other hand, Fermin contends thatsince the CA found that the penalty of dismis-sal was not proportionate to his offense, itshould have ruled in favor of his entitlement tobackwages.

ISSUE:

Whether or not the imposition of thepenalty of dismissal was appropriate.

HELD:

The Court ruled in the affirmative.

It must be noted that in the case at bar,

all the lower tribunals were in agreementthat Fermins act of taking Bragas cell-phone amounted to theft. Factual findingsmade by administrative agencies, if estab-lished by substantial evidence as borne outby the records, are final and binding on thisCourt, whose jurisdiction is limited to re-viewing questions of law. Theft committedagainst a co-employee is considered as acase analogous to serious misconduct, forwhich the penalty of dismissal from service

may be meted out to the erring employ-ee,viz:

Article 282 of the Labor Codeprovides:

Article 282. Termination by Em-ployer. -An employer may terminate anemployment for any of the followingcauses:

(a)Serious misconductor wil-

ful disobedience by the employee ofthe lawful orders of his employer or hisrepresentativesin connection withhis work;

x xx x xx x xx

(e) Other causes analogous tothe foregoing.

G.R. No. 189999 June 27, 2012ANGELES UNIVERSITY FOUNDA-

TION,Petitioner,vs.

CITY OF ANGELES, JULIET G. QUINSAAT,in her capacity as Treasurer of Angeles


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JURISPRUDENCECity and ENGR. DONATO N. DIZON, in hiscapacity as Acting Angeles City Building

Official,Respondents.

FACTS:

Petitioner Angeles University Foundation(AUF) is an educational institution estab-lished on May 25, 1962 and was convertedinto a non-stock, non-profit education founda-tion under the provisions of Republic Act(R.A.) No. 6055 on December 4, 1975.

Sometime in August 2005, petitioner filed

with the Office of the City Building Official anapplication for a building permit for the con-struction of an 11-storey building of the Ange-les University Foundation Medical Center inits main campus.

Said office issued a Building Permit FeeAssessment in the amount of P126,839.20.An Order of Payment was also issued by theCity Planning and Development Office, Zon-ing Administration Unit requiring petitioner to

pay the sum of P238,741.64 as LocationalClearance Fee.

Petitioner claimed that it is exempt fromthe payment of the building permit and loca-tional clearance fees.

Respondent City Treasurer referred thematter to the Bureau of Local GovernmentFinance (BLGF) of the Department of Fi-nance, which in turn endorsed the query tothe DOJ. The DOJ Secretary declared peti-tioner to be exempt from the payment ofbuilding permit fees.

Petitioner wrote the respondents reiterating itsrequest to reverse the disputed assessmentshowever, despite petitioners plea, respond-ents refused to issue the building permit sothe petitioner paid the fees under protest, onlythen did the respondents issued the corre-sponding Building Permit, Writing Permit,Electrical Permit, and Sanitary Building Per-mit.

Petitioner then filed a complaint before theRTC seeking for the refund of what it has paid

plus interest and in its Answer, the respond-ents asserted that the claim of petitioner can-not be granted because its structures are notamong those mentioned in Sec. 209 oftheNational Building Codeas exempted fromthe building permit fee. Since the disputed as-sessments are regulatory in nature, they arenot taxes from which petitioner is exempt. Asto the real property taxes imposed on petition-ers property located in Marisol Village, re-spondents pointed out that said premises will

be used as a school dormitory which can-not be considered as a use exclusively foreducational activities.

The RTC rendered decision in favour ofthe petitioner. On appeal, the CA reversed thetrial courts decision holding that while the pe-titioner is a tax-free entity, it is not exemptfrom the payment of regulatory fees.

ISSUES:

1. Whether or not the Petitioner is exemptfrom the payment of building permitand related fees imposed under theNational Building Code.

2. Whether or not the parcel of landowned by the petitioner which has beenassessed for real property tax is like-wise exempt.

HELD:

1. No, Petitioner is not exempt.

Exempted from the payment ofbuilding permit fees are: (1) public build-ings and (2) traditional indigenous familydwellings.Not being expressly included inthe enumeration of structures to which thebuilding permit fees do not apply, petition-ers claim for exemption rests solely on its


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JURISPRUDENCEinterpretation of the term "other chargesimposed by the National Government" inthe tax exemption clause of R.A. No. 6055.

That a building permit fee is a regulatoryimposition is highlighted by the fact that inprocessing an application for a building per-mit, the Building Official shall see to it that theapplicant satisfies and conforms with ap-proved standard requirements on zoning andland use, lines and grades, structural design,sanitary and sewerage, environmental health,electrical and mechanical safety as well aswith other rules and regulations implementing

the National Building Code. Thus, ancillarypermits such as electrical permit, sanitarypermit and zoning clearance must also besecured and the corresponding fees paid be-fore a building permit may be issued. And ascan be gleaned from the implementing rulesand regulations of the National BuildingCode, clearances from various governmentauthorities exercising and enforcing regulato-ry functions affecting buildings/structures, likelocal government units, may be further re-

quired before a building permit may be is-sued.

Since building permit fees are not charges onproperty, they are not impositions from whichpetitioner is exempt.

As to petitioners argument that the buildingpermit fees collected by respondents are inreality taxes because the primary purpose isto raise revenues for the local governmentunit, the same does not hold water.

2. The real property of the peti-tioner in question is likewise not ex-empt.

Under the 1973 and 1987 Constitu-tions and Rep. Act No. 7160 in order tobe entitled to the exemption, the petition-er is burdened to prove, by clear and un-equivocal proof, that (a) it is a charitableinstitution; and (b) its real propertiesare

ACTUALLY,

DIRECTLY

and

EXCLU

SIVELYused for charitable purposes."Exclusive" is defined as possessed andenjoyed to the exclusion of others; de-

barred from participation or enjoyment;and "exclusively" is defined, "in a mannerto exclude; as enjoying a privilege exclu-sively." If real property is used for one ormore commercial purposes, it is not ex-clusively used for the exempted purposesbut is subject to taxation. The words"dominant use" or "principal use" cannotbe substituted for the words "used exclu-sively" without doing violence to the Con-stitutions and the law. Solely is synony-

mous with exclusively.

What is meant by actual, direct andexclusive use of the property for charita-ble purposes is the direct and immediateand actual application of the property it-self to the purposes for which the charita-ble institution is organized. It is not theuse of the income from the real propertythat is determinative of whether the prop-erty is used for tax-exempt purposes.

Petitioner failed to discharge its bur-

den to prove that its real property is actu-

ally, directly and exclusively used for edu-

cational purposes. While there is no alle-

gation or proof that petitioner leases

the land to its present occupants, still

there is no compliance with the constitu-

tional and statutory requirement that saidreal property is actually, directly and ex-

clusively used for educational purposes.

The respondents correctly assessed the

land for real property taxes for the taxa-

ble period during which the land is not

being devoted solely to petitioners edu-

cational activities.


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JLs Corner

In the state of nature indeed allmen are born equal but they can-

not continue in this equality. Socie-ty makes them lose it and they re-cover it only by the protection of

the laws.Charles de Montesquieu (1689 -

1755), The Spirit of Laws, 1748

V o l u m e I V I s s u e N o .6 J U N E 2012

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