June 14, 1993
Ponente: Quiason, J.
FACTS
SEA-LAND, an American international shipping company doing business in the Philippines, paid its income due. Subsequently, it filed a claim for refund, claiming it had paid by mistake. The CTA denied the company’s refund claim.
RULING
The SC ruled for the CTA.
The business conducted by SEA-LAND does not fall under the “construction, maintenance, operation and defense of the bases,” which is the coverage for tax exemption. Laws granting exemption from tax are construed strictissimi juris against the taxpayer and liberally in favor of the taxing power.
Taxation is the rule and exemption is the exception. The law does not look with favor on tax exemptions and that he who would seek to be thus privileged must justify it by words too plain to be mistaken and too categorical to be misinterpreted.
