FACTS
Following his failure to file his income tax returns for the years 1945 and 1946, Yuseco was assessed by the CIR collector the sums of P134.14 and P7,563.28 representing alleged income taxes and corresponding surcharges.
The succeeding reinvestigations upon the instance of Yuseco and the demands made by the CIR in the succeeding years eventually led to the CIR issuing a warrant of distraint and levy upon Yuseco's properties.
As a response, Yuseco filed a petition for prohibition before the CTA, which nullified the CIR's warrant of distraint and levy. Hence, CIR's petition before the SC.
RULING
The Supreme Court ruled in favor of the CIR.
The CTA's decision must be nullified because nowhere does the law expressly vest in the CTA original jurisdiction to issue writs of prohibition and injunction independently of, and apart from, an appealed case. Note that taxes, being the chief source of revenue for the Government to keep it running, must be paid immediately and without delay.
A taxpayer who feels aggrieved by the decision of a revenue officer and appeals to the CTA must pay the tax assessed, except that, if in the opinion of the Court the collection would jeopardize the interest of the Government and/or the taxpayer, it could suspend the collection and require the taxpayer either to deposit the amount claimed or to file a surety bond for not more than double the amount of the tax assessed.
