Friday, February 24, 2012

Lutz vs. Araneta [December 22, 1955, (98 Phil 148)]

Facts: Commonwealth Act No. 567, otherwise known as Sugar Adjustment Act was promulgated in 1940 “to stabilize the sugar industry so as to prepare it for the eventuality of the loss of its preferential position in the United States market and the imposition of export taxes.” Plaintiff, Walter Lutz, in his capacity as Judicial Administrator of the Intestate Estate of Antonio Jayme Ledesma, seeks to recover from the Collector of Internal Revenue the sum of P14,666.40 paid by the estate as taxes, under Sec.3 of the Act, alleging that such tax is unconstitutional and void, being levied for the aid and support of the sugar industry exclusively, which in plaintiff’s opinion is not a public purpose for which a tax may be constitutionally levied. The action has been dismissed by the Court of First Instance. 

Issue: Whether or not the tax imposed is constitutional. 

Held: Yes. The act is primarily an exercise of the police power. It is shown in the Act that the tax is levied with a regulatory purpose, to provide means for the rehabilitation and stabilization of the threatened sugar industry. 

It is inherent in the power to tax that a state be free to select the subjects of taxation, and it has been repeatedly held that “inequalities which result from a singling out of one particular class for taxation or exemption infringe no constitutional limitation.” 

The funds raised under the Act should be exclusively spent in aid of the sugar industry, since it is that very enterprise that is being protected. It may be that other industries are also in need of similar protection; but the legislature is not required by the Constitution to adhere to a policy of “all or none.” 

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