06-02-2019, 12:01 PM
In Commissioner of Internal Revenue v. Primetown Property Group, Inc. (GR 162155, August 28, 2007), we said that as between the Civil Code, which provides that a year is equivalent to 365 days, and the Administrative Code of 1987, which states that a year is composed of 12 calendar months, it is the latter that must prevail following the legal maxim, Lex posteriori derogat priori. (Cited in CIR v. AICHI FORGING COMPANY, G.R. No. 184823, October 6, 2010)