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Sison V. Anchetagr No. L-59431 25 July 1984F A C T S

BP 135 imposed higher tax rates on income earned by professionals. Sison, a taxpayer, alleged that this provision unduly discriminated against him and violated the equal protection and due process clauses of the Constitution as well as the rule of uniformity in taxation. The Supreme Court held that there was no violation because the taxing power can reasonably classify taxpayers for taxation purposes. Professionals and those earning compensation income can be classified differently as professionals have variable expenses to generate income unlike those with compensation income. Thus, applying a gross income tax system to compensation but a net income tax system to professionals is justified.

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0% found this document useful (0 votes)
55 views1 page

Sison V. Anchetagr No. L-59431 25 July 1984F A C T S

BP 135 imposed higher tax rates on income earned by professionals. Sison, a taxpayer, alleged that this provision unduly discriminated against him and violated the equal protection and due process clauses of the Constitution as well as the rule of uniformity in taxation. The Supreme Court held that there was no violation because the taxing power can reasonably classify taxpayers for taxation purposes. Professionals and those earning compensation income can be classified differently as professionals have variable expenses to generate income unlike those with compensation income. Thus, applying a gross income tax system to compensation but a net income tax system to professionals is justified.

Uploaded by

mavslastimoza
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© © All Rights Reserved
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Sison v. AnchetaGR No.

L-59431; 25 July 1984F A C T S:

Batas Pambansa 135


was enacted. Sison, astaxpayer, alleged that its provision (Section 1) unduly discriminated against him by
the imposition of higher ratesupon his income as a professional, that it amounts to
classlegislation, and that it transgresses against the equalprotection and due process clauses of the
Constitution as wellas the rule requiring uniformity in taxation.

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.

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