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	GR No. 188497 2014-02-19	CIR v. PILIPINAS SHELL PETROLEUM CORPORATION VILLARAMA, JR., J.
As to respondent's reliance in the cases of Silkair (Singapore) Pte. Ltd. v. Commissioner of Internal Revenue[3] and Exxonmobil Petroleum & Chemical Holdings, Inc.-Philippine Branch v. Commissioner of Internal Revenue,[4] the Solicitor General points out that there was no pronouncement in these cases that petroleum manufacturers selling petroleum products to international carriers are exempt from paying excise taxes. In fact, Exxonmobil even cited the case of Philippine Acetylene Co, Inc. v. Commissioner of Internal Revenue.[5] Further, the ruling in Maceda v. Macaraig, Jr.[6] which confirms that Section 135 does not intend to exempt manufacturers or producers of petroleum products from the payment of excise tax.