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Paper Industries Corporation of the Philippines (PICOP) vs. Court of Appeals [CONCURRING OPINION, VITUG, J.]

PAPER INDUSTRIES CORPORATION OF THE PHILIPPINES (PICOP), petitioner, vs. COURT OF APPEALS, COMMISSIONER OF INTERNAL REVENUE and COURT OF TAX APPEALS, respondents.

G.R. Nos. 106949-50 | 1995-12-01

Separate Opinions 

VITUG, J., concurring: 

In usual erudite manner, Mr. Justice Florentino P. Feliciano has written for the Court the ponencia that presents in clear and logical sequence the issues, the facts and the law involved. While I share, in most part, the conclusions expressed in the opinion, I regrettably find it difficult, nevertheless, not to propose a re-examination of the Court's holding in Western Minolco Corporation vs. Commissioner of Internal Revenue (124 SCRA 121), reiterated in Marinduque Mining and Industrial Corporation vs. Commissioner of Internal Revenue (137 SCRA 88), that has taken the 35% transaction tax...