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Commissioner of Internal Revenue Vs. SM Prime Holdings, Inc., et al.

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus SM PRIME HOLDINGS, INC. and FIRST ASIA REALTY DEVELOPMENT CORPORATION, Respondents

G.R. No. 183505 | 2010-02-26

D E C I S I O N


DEL CASTILLO, J.:

When the intent of the law is not apparent as worded, or when the application of the law would lead to absurdity or injustice, legislative history is all important. In such cases, courts may take judicial notice of the origin and history of the law,[1] the deliberations during the enactment,[2] as well as prior laws on the same subject matter[3] to ascertain the true intent or spirit of the law.

This Petition for Review on Certiorari under Rule 45 of the Rules of Court, in relation to Republic Act (RA) No. 9282,[4] seeks to set aside the April 30, 2008 Decision[5] and the June 24, 2008 Resolution[6] of...