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Manila Electric Company vs. Vera 67 SCRA 352

MANILA ELECTRIC COMPANY, petitioner, vs. MISAEL P. VERA, in his capacity as Commissioner of Internal Revenue, respondent.

G.R. No. L-29987 | 1975-10-22

D E C I S I O N

MUá'OZ PALMA, J:

Manila Electric Company, petitioner in these two cases, poses a single issue before Us: is Manila Electric Company (MERALCO for short) exempt from payment of a compensating tax on poles, wires, transformers, and insulators imported by it for use in the operation of its electric light, heat, and power system? MERALCO answers the query in the affirmative while the Commissioner of Internal Revenue asserts the contrary.

MERALCO is the holder of a franchise to construct, maintain, and operate an electric light, heat, and power system in the City of Manila and its suburbs. 1

In 1962, MERALCO imported and received...