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Linconl Phil. Life Ins. Co. Inc. Vs. CA, et al.

LINCOLN PHILIPPINE LIFE INSURANCE COMPANY INC. (now JARDINE-CMG LIFE INSURANCE CO. INC.), petitioner, vs. COURT OF APPEALS and COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. 118043 | 1998-07-23

D E C I S I O N

MENDOZA, J:

This is a petition for review on certiorari of the decision rendered on November 18, 1994 by the Court of Appeals 1 reversing, in part, the decision of the Court of Tax Appeals in C.T.A. Case No. 4583.

The facts are not in dispute. 2 Petitioner, now the Jardine-CMG Life Insurance Company, Inc., is a domestic corporation engaged in the life insurance business. In 1984, it issued 50,000 shares of stock as stock dividends, with a par value of P100 or a total of P5 million. Petitioner paid documentary stamp taxes on each certificate on the basis of its par value. The question in this case is whether in...