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CONSUELO P. BORJA v. COLLECTOR OF INTERNAL REVENUE

This case has been cited 1 times or more.

2009-02-27
BRION, J.
The basic principle in the construction of laws granting tax exemptions has been very stable. As early as 1916, in the case of Government of the Philippine Islands v. Monte de Piedad,[5] this Court has declared that he who claims an exemption from his share of the common burden of taxation must justify his claim by showing that the Legislature intended to exempt him by words too plain to be beyond doubt or mistake. This doctrine was repeated in the 1926 case of Asiatic Petroleum v. Llanes,[6] as well as in the case of Borja v. Commissioner of Internal Revenue (CIR)[7] decided in 1961. Citing American jurisprudence, the Court stated in E. Rodriguez, Inc. v. CIR:[8]