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	GR No. 189999 2012-06-27	ANGELES UNIVERSITY FOUNDATION v. CITY OF ANGELES VILLARAMA, JR., J.
A charge of a fixed sum which bears no relation at all to the cost of inspection and regulation may be held to be a tax rather than an exercise of the police power.[26] In this case, the Secretary of Public Works and Highways who is mandated to prescribe and fix the amount of fees and other charges that the Building Official shall collect in connection with the performance of regulatory functions,[27] has promulgated and issued the Implementing Rules and Regulations[28] which provide for the bases of assessment of such fees, as follows: Character of occupancy or use of building
	GR NO. 159796 2007-07-17	ROMEO P. GERICHI v. DEPARTMENT OF ENERGY (DOE) NACHURA, J.
The conservative and pivotal distinction between these two powers rests in the purpose for which the charge is made. If generation of revenue is the primary purpose and regulation is merely incidental, the imposition is a tax; but if regulation is the primary purpose, the fact that revenue is incidentally raised does not make the imposition a tax.[36]