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BPI-Family Savings Bank,Inc. vs CA,CTA & CIR

BPI-FAMILY SAVINGS BANK, Inc., petitioner, vs. COURT OF APPEALS, COURT OF TAX APPEALS and the COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. 122480 | 2000-04-12

D E C I S I O N


PANGANIBAN, J.:

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.


The Case

Before us is a Petition for Review assailing the March 31, 1995 Decision of the Court of Appeals1 [Fourth Division, composed of JJ. Quirino D. Abad Santos Jr. (ponente), Gloria C. Paras (chairman) and Delilah...