06-02-2019, 02:52 PM
The CIR erred in applying the principles of tax exemption without first applying the well-settled doctrine of strict implementation in the imposition of taxes. It is both illogical and impractical to determine who are exempted without FIRST determining who are covered b the aforesaid provisions. As such, it must be determined first if the person is covered by the tax law, applying the rule of strict interpretation of laws imposing taxes and other burdens on the populace, before asking the same person to prove his exemption therefor (CIR vs. CA, GR No. 115349, April 18, 1997).