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Philippine Phosphate Fertilizer Corporation vs Commissioner of Internal Revenue

PHILIPPINE PHOSPHATE FERTILIZER CORPORATION, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 141973 | 2005-06-28

D E C I S I O N 


AUSTRIA-MARTINEZ, J.: 


Once more, we stand by our ruling that: 

If the State expects its taxpayers to observe fairness and honesty in paying their taxes, so must it apply the same standard against itself in refunding excess payments. When it is undisputed that a taxpayer is entitled to a refund, the State should not invoke technicalities to keep money not belonging to it. No one, not even the State, should enrich oneself at the expense of another.[1] 

The antecedents of this case are as follows: 

Philippine Phosphate Fertilizer Corporation (Philphos) is a domestic corporation registered with the...