06-02-2019, 02:49 PM
Laws granting tax exemption are construed in strictissimi juris against the taxpayer and liberally in favor of the taxing power. Taxation is the rule and exemption is the exception. The law does not look with favor on tax exemptions and that he who would seek to be thus privileged must justify it by words too plain to be mistaken and too categorical to be misinterpreted (Sea Land Service, Inc. vs CA, GR 57828, June, 14, 1993; PAGCOR vs. BIR, GR No. 172087, March 15, 2011.