Thursday, September 22, 2016

Elegado v. CA G.R. No. 68385; May 12, 1989


ELEGADO v. CA
Doctrine:

Facts:
Warren Taylor Graham, an American national formerly resident in the Philippines, died in Oregon, U.S.A.

As he left certain shares of stock in the Philippines, his son, Ward Graham, filed an estate tax return with the Philippine Revenue Representative in San Francisco, U.S.A.

The respondent CIR assessed the decedent's estate an estate tax in the amount of P96,509.35. This assessment was protested by the law firm of Bump, Young and Walker on behalf of the estate.

The protest was denied by the Commissioner. No further action was taken by the estate in pursuit of that protest.

The decedent's will had been admitted to probate in the Circuit Court of Oregon. Ward Graham, the designated executor, then appointed Ildefonso Elegado, the herein petitioner, as his attorney-in-fact for the allowance of the will in the Philippines.

Petitioner commenced probate proceedings and the will was allowed, with the petitioner as ancillary administrator. As such, he filed a second estate tax return with the BIR.

On the basis of this second return, the Commissioner imposed an assessment on the estate in the amount of P72,948.87 which was protested on behalf of the estate by the Agrava, Lucero and Gineta Law Office.

While this protest was pending, the Commissioner filed in the probate proceedings a motion for the allowance of the basic estate tax of P96,509.35 as previously assessed. He said that this liability had not yet been paid although the assessment had long become final and executory.

The petitioner regarded this motion as an implied denial of the protest against the second assessment of P72,948.87. On this understanding, he filed a petition for review with the Court of Tax Appeals challenging the said assessment.
The Commissioner did not immediately answer (in fact, as the petitioner stressed, no answer was filed during a delay of 195 days) and in the end instead canceled the protested assessment. This cancellation was notified to the Court of Tax Appeals in a motion to dismiss on the ground that the protest had become moot and academic.

The motion was granted and the petition dismissed. The petitioner then came to this Court on certiorari under Rule 45 of the Rules of Court.

Issue:
whether or not the respondent Court of Tax Appeals erred in dismissing the petitioner's appeal on grounds of jurisdiction and lack of a cause of action.- NO

-whether the appeal filed with the respondent court should be considered moot and academic. YES

Ruling:
In the letter to the decedent's estate, the Commissioner of Internal Revenue requested for the settlement of the assessment for P96,509.35 within fifteen (15) days upon receipt  and also expressly cancelled the assessment for P72,949.57.

It is obvious from the express cancellation of the second assessment for P72,948.87 that the petitioner had been deprived of a cause of action as it was precisely from this assessment that he was appealing.

The petitioner argues that the issuance of the second assessment had the effect of canceling the first assessment and that the subsequent cancellation of the second assessment did not have the effect of automatically reviving the first. Moreover, the first assessment is not binding on him because it was based on a return filed by foreign lawyers who had no knowledge of our tax laws or access to the Court of Tax Appeals.

It is noted that in the letter imposing the second assessment of P72,948.87, the Commissioner made it clear that "the aforesaid amount is considered provisional only based on the estate tax return filed subject to investigation by this Office for final determination of the correct estate tax due from the estate. Any amount that may be found due after said investigation will be assessed and collected later." It is illogical to suggest that a provisional assessment can supersede an earlier assessment which had clearly become final and executory.

The most compelling consideration in this case is the fact that the first assessment is already final and executory and can no longer be questioned at this late hour. The assessment was made on February 9, 1978. It was protested on March 7, 1978. The protest was denied on July 7, 1978. As no further action was taken thereon by the decedent's estate, there is no question that the assessment has become final and executory.

In fact, the law firm that had lodged the protest appears to have accepted its denial. In his motion with the probate court, the respondent Commissioner stressed that "in a letter dated January 29, 1980, the Estate of Warren Taylor Graham thru the aforesaid foreign law firm informed claimant that they have paid said tax liability thru the Agrava, Velarde, Lucero and Puno, Philippine law firm that initiated the instant ancillary proceedings" although he added that such payment had not yet been received. This letter was an acknowledgment by the estate of the validity and finality of the first assessment. Significantly, it has not been denied by the petitioner.

In view of the finality of the first assessment, the petitioner cannot now raise the question of its validity before this Court any more than he could have done so before the Court of Tax Appeals. What the estate of the decedent should have done earlier, following the denial of its protest on July 7, 1978, was to appeal to the Court of Tax Appeals within the reglementary period of 30 days after it received notice of said denial. It was in such appeal that the petitioner could then have raised the first two issues he now raises without basis in the present petition.


If indeed the Commissioner of Internal Revenue committed an error in the computation of the estate tax, as the petitioner insists, that error can no longer be rectified because the original assessment has long become final and executory. If that assessment was not challenged on time and in accordance with the prescribed procedure, that error - for error it was - was committed not by the respondents but by the decedent's estate itself which the petitioner represents.

No comments:

Post a Comment