sic itur ad astra

  Taxation The estate of Walter Scott Price was assessed inheritance taxes amounting to ₱40,058.55. The Court of First Instance of Leyte ordered payment of the taxes, but later deferred execution, reasoning that the government itself owed the estate ₱262,200 under Republic Act No. 2700 for services rendered in the Leyte Cadastral Survey . The trial court held that the government should first pay its debt to the estate before insisting on immediate collection of taxes. The Commissioner of Internal Revenue (Domingo) filed a petition for certiorari and mandamus to compel execution of the tax judgment. Whether the government could immediately execute collection of inheritance taxes against the estate despite its own outstanding debt to the estate. The Supreme Court denied the petition, holding that execution was not the proper remedy in probate proceedings. Claims for taxes against an estate must be settled through the probate court, which has jurisdiction over estate properties...

Taxation Engracio Francia owned a residential lot with a two-story house in Pasay City but failed to pay real property taxes from 1963 to 1977, incurring a tax delinquency of ₱2,400.00. On October 15, 1977, a 125-square-meter portion of his property was expropriated by the Republic of the Philippines for ₱4,116.00 , which amount was deposited with the Philippine National Bank in his name. Due to the unpaid real property taxes, Francia’s remaining property was sold at a public auction on December 5, 1977, where Ho Fernandez emerged as the highest bidder. Francia received notice of the auction sale but did not attend, claiming he was in Iligan City at the time and later sought to annul the sale. Francia argued that his tax delinquency had already been extinguished by legal compensation because the government owed him more than the amount of his unpaid taxes due to the expropriation. Whether Francia’s unpaid real property taxes could be extinguished by legal compensation or set-off agains...