THIRD DIVISION
DECISION
ABAD,J.:
This case is about the distinction between an action contesting a local tax assessment and an action seeking to enjoin the local government from enforcing a tax assessment against a person who claims that the taxable business does not belong to him.
The Facts and the Case
On March 28, 2003 petitioner National Power Corporation (NPC) received a notice of franchise tax delinquency from the respondent Provincial Government of Bataan (the Province) for P45.9 million covering the years 2001, 2002, and 2003. The Province based its assessment on the NPC’s sale...
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