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Department of Finance and Department of Energy vs. PAL

DEPARTMENT OF FINANCE AND DEPARTMENT OF ENERGY, PETITIONERS, VS. PHILIPPINE AIRLINES, INC., RESPONDENT. G.R. No. 229812 THE DEPARTMENT OF FINANCE AND THE DEPARTMENT OF ENERGY, PETITIONERS, VS. PHILIPPINE AIRLINES, INC., RESPONDENT.

G.R. Nos. 198609-10 | 2023-04-26

D E C I S I O N
 
LEONEN, J.:
 
A ruling of the Bureau of Internal Revenue cannot be indirectly attacked to escape tax liability by questioning one of its factual bases before the Regional Trial Court. Regular courts generally do not have jurisdiction to pass upon issues involving matters arising from the administration of tax laws.

This involves consolidated cases docketed as G.R. Nos. 198609-10 and G.R. No. 229812 that originate from a common factual background. G.R. Nos. 198609-10 is a Petition for Review seeking to reverse and set aside the Court of Appeals Consolidated Decision,[1] which dismissed Petitions for ...