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Commissioner Of Internal Revenue vs. Leonardo S. Villa, Et Al.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. LEONARDO S. VILLA and THE COURT OF TAX APPEALS, respondents.

G.R. No. L-23988 | 1968-01-07

D E C I S I O N 


BENGZON, J.P., J.: 

Jurisdiction over the subject matter is fundamental for a court to act on a given controversy. It is conferred by law, 1 not by consent of the parties. 2 It can be challenged at any stage of the proceedings and for lack of it, a court can dismiss a case ex mero motu. 3 

To inquire into the existence of jurisdiction over the subject matter is the primary concern of a court, for thereon would depend the validity of its entire proceedings. In this case, the parties submitted voluntarily to the jurisdiction of the Court of Tax Appeals, adduced their evidence thereat. Thereafter, they submitted...