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BENGUET CORPORATION v. CENTRAL BOARD OF ASSESSMENT APPEALS

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GR No. 168584
2007-10-15
REPUBLIC v. RAMON S. CAGUIOA
CARPIO MORALES, J.
Third. As a general rule, tax exemptions are construed strictissimi juris against the taxpayer and liberally in favor of the taxing authority.[34] The burden of proof rests upon the party claiming exemption to prove that it is in fact covered by the exemption so claimed.[35]  In case of doubt, non-exemption is favored.[36]