DIGEST - Gomez vs. Palomar

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Gomez vs.

Palomar
G.R. No. L-23645
October 29, 1968

Facts
Petitioner questions the constitutionality of the statute, claiming that RA 1635, otherwise known
as the Anti-TB Stamp Law, is violative of the equal protection clause of the Constitution because it
constitutes mail users into a class for the purpose of the tax while leaving untaxed the rest of the
population and that even among postal patrons the statute discriminatorily grants exemptions.
Moreover, petitioner contends that the statutory classification of taxpayers has no relation to the
object sought by the Anti-TB law.

Issue
Whether or not the Anti-TB law violates the equal protection clause of the Constitution.

Ruling
No. The Supreme Court reiterated that the legislature has the inherent power to select the
subjects of taxation and to grant exemptions. The reason for this is that traditionally, classification has
been a device for fitting tax programs to local needs and usages in order to achieve an equitable
distribution of the tax burden. That legislative classifications must be reasonable is, of course, undenied
in this case.
The classification of mail users is not without any reason. It is based on ability to pay, let alone the
enjoyment of a privilege, and on administrative convenience. The classification is likewise based on
considerations of administrative convenience. For it is now a settled principle of law that “consideration
of practical administrative convenience and cost in the administration of tax laws afford adequate ground
for imposing a tax on a well-recognized and defined class.” Lastly, mail users were already a class by
themselves even before the enactment of the statute, and all that the legislature did was merely to select
their class.
Petitioner’s assertions that statutory classification of mail users must bear some reasonable
relationship to the end sought to be attained and that absent such relationship the selection of mail users
is constitutionally impermissible do not hold water. This is altogether a different proposition as explained
by the court “that while the principle that there must be a reasonable relationship between classification
made by the legislation and its purpose is undoubtedly true in some contexts, it has no application to a
measure whose sole purpose is to raise revenue, so long as the classification imposed is based upon some
standard capable of reasonable comprehension, be that standard based upon ability to produce revenue
or some other legitimate distinction, equal protection of the law has been afforded.”

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