Sison V. Anchetagr No. L-59431 25 July 1984F A C T S
Sison V. Anchetagr No. L-59431 25 July 1984F A C T S
I S S U E:
Whether or not BP 135 violates the due processand equal protection clauses, and the rule on uniformity
intaxation.
H E L D:
There is a need for proof of such persuasivecharacter as would lead to a conclusion that there
was a violation of the due process and equal protection clauses. Absent such showing, the presumption
of validity must prevail.Equality and uniformity in taxation means that all taxablearticles or kinds of
property of the same class shall be taxed atthe same rate. The taxing power has the authority to
makereasonable and natural classifications for purposes of taxation. Where the differentiation conforms
to the practical dictates of justice and equity, similar to the standards of equal protection,it is not
discriminatory within the meaning of the clause and istherefore uniform. Taxpayers may be classified
into differentcategories, such as recipients of compensation income asagainst professionals. Recipients
of compensation income arenot entitled to make deductions for income tax purposes asthere is no
practically overhead expense, while professionalsand businessmen have no uniform costs or expenses
necessary to produce their income. There is ample justification to adoptthe gross system of income
taxation to compensation income, while continuing the system of net income taxation as
regardsprofessional and business income.