LIFEBLOOD THEORY

CIR v. BPI
521 SCRA 373, 387- 388

x x x (T)he public will suffer if taxpayers will not be held liable for the proper taxes assessed against
them: "Taxes are the lifeblood of the government, for without taxes, the government can neither
exist nor endure. " A principal attribute of sovereignty, the exercise of taxing power derives its
source from the very existence of the state whose social contract with its citizens obliges it to
promote public interest and common good. The theory behind the exercise of the power to tax
emanates from necessity; without taxes, government cannot fulfill its mandate of promoting the
general welfare and well-being of the people.

LIFEBLOOD THEORY
DAVAO GULF LUMBER CORP. v CIR
293 SCRA 77

Because taxes are the lifeblood of the nation, statutes that allow exemptions are construed
strictly against the grantee and liberally in favor of the government. Otherwise stated, any exemption
from the payment of a tax must be clearly stated in the language of the law; it cannot be merely
implied therefrom.

LIFEBLOOD THEORY
FERDINAND R. MARCOS II v. CA, et al.
273 SCRA 47

Ferdinand R.Marcos II assailed the decision of the Court of Appeal declaring the deficiency
income tax assessments and estate tax assessments upon the estate and properties of his late father
final despite the pendency of the probate proceedings of the will of the late President. On the other
hand, the BIR argued that the State's authority to collect internal revenue taxes is paramount.

JOSE REYES v. PEDRO ALMANZOR

196 SCRA 322

Verily, taxes are the lifeblood of the government and should be collected without
unnecessary hindrance. However, such collection should be made in accordance with law as any
arbitrariness will negate the very reason for government itself. It is therefore necessary to reconcile
the apparently conflicting interests of the authorities and the taxpayers so that the real purpose of
taxation, which is the promotion of the common good, may be achieved. ( CIR v. Algue, Inc., 158
SCRA 9 [1988])

Consequently, it stands to reason that petitioners who are burdened by the government by
its Rental Freezing Laws (R.A No. 6359 and P.D. No. 20) under the same principle of social justice
should not now be penalized by the same government by the imposition of excessive taxes
petitioners can ill afford and eventually result in the forfeiture of their properties.

PHILIPPINE GUARANTY CO., INC. v. CIR

13 SCRA 775

The defense of reliance in good faith on rulings of the CIR requiring no withholding of tax
due on reinsurance premiums may free the taxpayer from the payment of surcharge or penalties
imposed for failure to pay the corresponding withholding tax, but it certainly would not exculpate
it from liability to pay such withholding tax. The Government is not estopped from collecting taxes
by the mistakes or errors of its agents.

PHILEX MINING CORPORATION v. CIR

294 SCRA 687

Philex posits the theory that it had no obligation to pay the excise tax liabilities within the
prescribed period since, after all, it still has pending claims for VAT input credit/ refund with BIR.

We fail to see the logic of Philex's claim for this is an outright disregard of the basic
principle in tax law that taxes are the lifeblood of the government and so should be collected without
unnecessary hindrance. Evidently, to countenance Philex's whimsical reason would render
ineffective our tax collection system. Too simplistic, it finds no support in law or in jurisprudence.

PHILIPPINE BANK OF COMMUNICATIONS v. CIR

302 SCRA 250

Basic is the principle that "taxes are the lifeblood of the nation." The primary purposes is
to generate funds for the State to finance the needs of the citizenry and to advance the common
weal. Due process of law under the Constitution does not require judicial proceedings in tax cases.
This must necessarily be so because it is upon taxation that the government chiefly relies to obtain
the means to carry on its operations and it is of utmost importance that the modes adopted to enforce
the collection of taxes levied should be summary and interfered with as little as possible.

From the same perspective, claims for refund or tax credit should be exercised within the
time fixed by law because the BIR being an administrative body enforced to collect taxes, its
functions should not be unduly delayed or hampered by incident matters.