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Commissioner of Internal Revenue vs. Manila Electric Company

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus MANILA ELECTRIC COMPANY, Respondent.

G.R. No. 121666 | 2007-10-10

D E C I S I O N
 

CARPIO MORALES, J.:

Assailed via Petition for Review is the Court of Appeals Decision[1] of August 23, 1995, affirming that of the Court of Tax Appeals dated January 6, 1995[2] which ordered petitioner, Commissioner of Internal Revenue, "to refund or, in the alternative, issue a tax credit certificate in favor of [respondent Manila Electric Company] the sum of P107,649,729.00 representing overpaid income taxes for the years 1987 and 1988."

Manila Electric Company (respondent), a grantee of a legislative franchise under Act No. 484, as amended by Republic Act No. 4159 and Presidential Decree No. 551,[3] had been...