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MANILA RAILROAD COMPANY v. INSULAR COLLECTOR OF CUSTOMS

This case has been cited 1 times or more.

2014-10-01
LEONEN, J.
Generally, tax statutes are construed strictly against the government and in favor of the taxpayer. [52] "[Statutes levying taxes or duties [are] not to extend their provisions beyond the clear import of the language used";[53] and "tax burdens are not to be imposed, nor presumed to be imposed beyond what the statute[s] expressly and clearly [import]. . . ."[54] Similarly, we cannot impose a penalty for non-payment of a tax greater than what the law provides.[55] To do so would amount to a deprivation of property without due process of law.