Lutz v. Araneta, G.R. No. L-7859, December 22, 1955

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Lutz v.

Araneta; Power of Taxation

Republic of the Philippines


SUPREME COURT
Manila
EN BANC

G.R. No. L-7859        December 22, 1955

WALTER LUTZ, as Judicial Administrator of the Intestate Estate of the deceased Antonio
Jayme Ledesma, plaintiff-appellant,

vs.

J. ANTONIO ARANETA, as the Collector of Internal Revenue, defendant-appellee.


Ernesto J. Gonzaga for appellant.
Office of the Solicitor General Ambrosio Padilla, First Assistant Solicitor General
Guillermo E. Torres and Solicitor Felicisimo R. Rosete for appellee.

REYES, J.B L., J.:

Facts:

Plaintiff Walter Lutz (Lutz), acting as Judicial Administrator of the Intestate Estate
of one Antonio Jayme Ledesma, is seeking to recover from the Collector of Internal
Revenue the sum of P14,666.40, paid by the estate as taxes, under Section 3 of the
Commonwealth Act No. 567 (CA 567) or the Sugar Adjustment Act. Section 3 levies on
the owners or persons in control of lands devoted to the cultivation of sugar cane taxes
that are equivalent to the difference between the money value of the rental and the
amount representing 12 per centum of the assessed value of such land. Lutz alleged that
such taxes are unconstitutional and void, being levied for the the aid and support of the
sugar industry exclusively. He further alleged that such industry does not belong under
the realm of public purpose hence taxes may not be constitutionally levied. The action
was dismissed by the Court of First Instance. Lutz appealed directly to this Court as
provided for in Section 17 of the Judiciary Act.

Issue: Whether or not the taxes being levied, as provided for in CA 567, is a pure
exercise of the taxing power and is thereby constitutional.

Ruling:

YES. The taxes imposed are constitutional for they are products of the exercise of
the government’s taxing power.

The taxes being levied are for a regulatory purpose - to provide means for the
rehabilitation and stabilization of the threatened sugar industry. The Court has taken
notice that the sugar industry is one of the great industries of the nation. Sugar occupies
the lead position among other products that are being exported. The sugar industry is a
great source of the state’s wealth. The importance of the sugar industry truly compels
the Government to take consideration of its promotion, protection, and advancement,
further redounding greatly to the general welfare. Hence, the legislature, in enacting CA
567, was competent for demanding the sugar industry be stabilized.

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