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Commissioner Of Internal Revenue Vs. Rio Tuba Nickel Mining Corporation, Et Al.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. RIO TUBA NICKEL MINING CORPORATION and COURT OF TAX APPEALS, respondents. Carpio, Villaraza & Cruz for private respondent.

G.R. No. 83583-84 | 1991-09-30

D E C I S I O N


FERNAN, J.:

Edmund Burke once said laws, like houses, lean on one another. The question concerning their repeal then becomes difficult especially when the new law does not expressly provide for the repeal of the old law. Whether or not Republic Act No. 1435 (An Act To Provide Means of Increasing the Highway Special Fund) or certain provisions thereof have been repealed by subsequent statutes is the problem now confronting us.

Private respondent Rio Tuba Nickel Mining Corporation is a domestic corporation engaged in the business of mining with several mining lease contracts entered into with the Republic of the...