estate of the late juliana diez vda. de gabriel vs. commissioner

8/18/2019 Estate of the Late Juliana Diez Vda. de Gabriel vs. Commissioner

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6/20/2015 SUPREME COURT REPORTS ANNOTATED VOLUME 421

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G.R. No. 155541. January 27, 2004.*

ESTATE OF THE LATE JULIANA DIEZ VDA. DEGABRIEL, petitioner, vs . COMMISSIONER OFINTERNAL REVENUE, respondent.

Taxation; Agency; The death of a taxpayer automaticallysevered the legal relationship between her and her agent, and suchcould not be revived by the mere fact that the agent continued toact as such when, two days after the principal’s death, the agent

filed the principal’s Income Tax Return. —The first point to beconsidered is that the relationship between the decedent andPhiltrust was one of agency , which is a personal relationshipbetween agent and principal. Under Article 1919 (3) of the CivilCode, death of the agent or principal automatically terminates theagency. In this instance, the death of the decedent on April 3,1979 automatically severed the legal relationship between herand Philtrust, and such could not be revived by the mere fact thatPhiltrust continued to act as her agent when, on April 5, 1979, it

filed her Income Tax Return for the year 1978. Since therelationship between Philtrust and the decedent wasautomatically severed at the moment of the Taxpayer’s death,none of Philtrust’s acts or omissions could bind the estate of theTaxpayer. Service on Philtrust of the demand letter and

Assessment Notice No. NARD-78-82-00501 was improperly done.It must be noted that Philtrust was never appointed as theadministrator of the Estate of the decedent, and, indeed, that thecourt a quo twice rejected Philtrust’s motion to be thus appointed.

As of November 18, 1982, the date of the demand letter and Assessment Notice, the legal relationship between the decedentand Philtrust had already been nonexistent for three years .

Same; Estate Tax; Section 104 of the Internal Revenue Code of 1977, requiring notice of death of taxpayer to be filed, falls in TitleIII, Chapter 1 and pertains to “all cases of transfers subject to tax” or where the “gross value of the estate exceeds three thousand

pesos” and has absolutely no

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* FIRST DIVISION.

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Estate of the Late Juliana Diez Vda. de Gabriel vs. Commissionerof Internal Revenue

applicability to a case for deficiency income tax. —Respondentclaims that Section 104 of the National Internal Revenue Code of 1977 imposed the legal obligation on Philtrust to inform

respondent of the decedent’s death. The said Section reads: SEC.104. Notice of death to be filed. —In all cases of transfers subject totax or where, though exempt from tax, the gross value of theestate exceeds three thousand pesos, the executor, administrator,or any of the legal heirs, as the case may be, within two monthsafter the decedent’s death, or within a like period after qualifyingas such executor or administrator, shall give written noticethereof to the Commissioner of Internal Revenue. The foregoingprovision falls in Title III, Chapter I of the National InternalRevenue Code of 1977, or the chapter on Estate Tax, and pertainsto “all cases of transfers subject to tax” or where the “gross valueof the estate exceeds three thousand pesos.” It has absolutely noapplicability to a case for deficiency income tax , such as the caseat bar. It further lacks applicability since Philtrust was never theexecutor, administrator of the decedent’s estate, and, as such,never had the legal obligation, based on the above provision, toinform respondent of her death.

Same; Same; Although the administrator of the estate mayhave been remiss in his legal obligation to inform respondent of the

decedent’s death, the consequences thereof, as provided in Section119 of the National Internal Revenue Code of 1977, merely refer tothe imposition of certain penal sanctions on the administrator .—

Although the administrator of the estate may have been remiss inhis legal obligation to inform respondent of the decedent’s death,the consequences thereof, as provided in Section 119 of theNational Internal Revenue Code of 1977, merely refer to theimposition of certain penal sanctions on the administrator. Thesedo not include the indefinite tolling of the prescriptive period for


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making deficiency tax assessments, or the waiver of the noticerequirement for such assessments.

Same; Tax Assessments; Prescription; Where there was neverany valid notice of an assessment, it could not have become final,executory and incontestable, and, for failure to make theassessment within the five-year period provided in Section 318 of the National Internal Revenue Code of 1977, the Commissioner of Internal Revenue’s claim against the taxpayer is barred. —Sincethere was never any valid notice of this assessment, it could nothave become final, executory and incontestable, and, for failure tomake the assessment within the five-year period provided inSection 318 of the National Internal Revenue Code of 1977,respondent’s claim against the petitioner Estate is barred. SaidSection 18 reads: SEC. 318. Period of limitation upon assessmentand collection. —Except as provided in the succeeding section,internal revenue taxes shall be assessed within five years after

the return was filed, and no proceeding in court withoutassessment for the collection of such taxes shall be begun afterthe expira-

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268 SUPREME COURT REPORTS ANNOTATED

Estate of the Late Juliana Diez Vda. de Gabriel vs. Commissionerof Internal Revenue

tion of such period. For the purpose of this section, a return filedbefore the last day prescribed by law for the filing thereof shall beconsidered as filed on such last day: Provided , That this limitationshall not apply to cases already investigated prior to the approvalof this Code.

Same; Same; Due Process; The rule that an assessment isdeemed made for the purpose of giving effect to such assessmentwhen the notice is released, mailed or sent to the taxpayer toeffectuate the assessment requires that the notice be sent to thetaxpayer, and not merely to a disinterested party. —Respondentargues that an assessment is deemed made for the purpose of giving effect to such assessment when the notice is released,mailed or sent to the taxpayer to effectuate the assessment, andthere is no legal requirement that the taxpayer actually receivesaid notice within the five-year period. It must be noted, however,that the foregoing rule requires that the notice be sent to the


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taxpayer , and not merely to a disinterested party. Although thereis no specific requirement that the taxpayer should receive thenotice within the said period, due process requires at the veryleast that such notice actually be received. In Commissioner of Internal Revenue v. Pascor Realty and Development Corporation ,we had occasion to say: An assessment contains not only acomputation of tax liabilities, but also a demand for payment

within a prescribed period. It also signals the time when penaltiesand interests begin to accrue against the taxpayer. To enable thetaxpayer to determine his remedies thereon, due process requiresthat it must be served on and received by the taxpayer .

Same; Same; Same; When an estate is under administration,notice must be sent to the administrator of the estate. —In Republicv. De le Rama , we clarified that, when an estate is underadministration, notice must be sent to the administrator of theestate, since it is the said administrator, as representative of the

estate, who has the legal obligation to pay and discharge all debtsof the estate and to perform all orders of the court. In that case,legal notice of the assessment was sent to two heirs, neither one of whom had any authority to represent the estate. We said: Thenotice was not sent to the taxpayer for the purpose of giving effectto the assessment, and said notice could not produce any effect. Inthe case of Bautista and Corrales Tan v. Collector of InternalRevenue . . . this Court had occasion to state that “the assessmentis deemed made when the notice to this effect is released, mailedor sent to the taxpayer for the purpose of giving effect to saidassessment.” It appearing that the person liable for the payment of the tax did not receive the assessment, the assessment could notbecome final and executory. (Citations omitted, emphasissupplied.)

PETITION for review on certiorari of a decision of theCourt of Appeals.

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Estate of the Late Juliana Diez Vda. de Gabriel vs.Commissioner of Internal Revenue

The facts are stated in the opinion of the Court. Magno & Associates for petitioner. The Solicitor General for respondent.


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YNARES-SANTIAGO, J. :

This petition for review on certiorari assails the decision of the Court of Appeals in CA-G.R. CV No. 09107, datedSeptember 30, 2002,

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which reversed the November 19,1995 Order of Regional Trial Court of Manila, BranchXXXVIII, in Sp. Proc. No. R-82-6994, entitled “Testate

Estate of Juliana Diez Vda. De Gabriel.” The petition wasfiled by the Estate of the Late Juliana Diez Vda. DeGabriel, represented by Prudential Bank as its dulyappointed and qualified Administrator.

As correctly summarized by the Court of Appeals, therelevant facts are as follows:

During the lifetime of the decedent, Juliana Vda. DeGabriel, her business affairs were managed by thePhilippine Trust Company (Philtrust). The decedent diedon April 3, 1979. Two days after her death, Philtrust,through its Trust Officer, Atty. Antonio M. Nuyles, filedher Income Tax Return for 1978. The return did notindicate that the decedent had died.

On May 22, 1979, Philtrust also filed a verified petitionfor appointment as Special Administrator with theRegional Trial Court of Manila, Branch XXXVIII, docketedas Sp. Proc. No. R-82-6994. The court a quo appointed oneof the heirs as Special Administrator. Philtrust’s motion forreconsideration was denied by the probate court.

On January 26, 1981, the court a quo issued an Orderrelieving Mr. Diez of his appointment, and appointed Antonio Lantin to take over as Special Administrator.Subsequently, on July 30, 1981, Mr. Lantin was alsorelieved of his appointment, and Atty. Vicente Onosa wasappointed in his stead.

In the meantime, the Bureau of Internal Revenueconducted an administrative investigation on thedecedent's tax liability and

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1 Rollo, pp. 111-117; penned by Associate Justice Portia Aliño-

Hormachuelos, concurred in by Associate Justices Elvi John S. Asuncion

and Juan Q. Enriquez, Jr.

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found a deficiency income tax for the year 1977 in theamount of P318,233.93. Thus, on November 18, 1982, theBIR sent by registered mail a demand letter and

Assessment Notice No. NARD-78-82-00501 addressed to

the decedent “c/o Philippine Trust Company, Sta. Cruz,Manila” which was the address stated in her 1978 IncomeTax Return. No response was made by Philtrust. The BIRwas not informed that the decedent had actually passedaway.

In an Order dated September 5, 1983, the court a quoappointed Antonio Ambrosio as the Commissioner and

Auditor Tax Consultant of the Estate of the decedent.On June 18, 1984, respondent Commissioner of Internal

Revenue issued warrants of distraint and levy to enforcecollection of the decedent’s deficiency income tax liability,which were served upon her heir, Francisco Gabriel. OnNovember 22, 1984, respondent filed a “Motion for

Allowance of Claim and for an Order of Payment of Taxes”with the court a quo. On January 7, 1985, Mr. Ambrosiofiled a letter of protest with the Litigation Division of theBIR, which was not acted upon because the assessmentnotice had allegedly become final, executory andincontestable.

On May 16, 1985, petitioner, the Estate of the decedent,through Mr. Ambrosio, filed a formal opposition to theBIR’s Motion for Allowance of Claim based on the groundthat there was no proper service of the assessment andthat the filing of the aforesaid claim had alreadyprescribed. The BIR filed its Reply, contending that serviceto Philippine Trust Company was sufficient service, andthat the filing of the claim against the Estate on November22, 1984 was within the five-year prescriptive period forassessment and collection of taxes under Section 318 of the1977 National Internal Revenue Code (NIRC).

On November 19, 1985, the court a quo issued an Orderdenying respondent’s claim against the Estate,

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afterfinding that there was no notice of its tax assessment onthe proper party.

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On July 2, 1986, respondent filed an appeal with theCourt of Appeals, docketed as CA-G.R. CV No. 09107,

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assailing the Order of the probate court dated November19, 1985. It was claimed that Philtrust, in filing the

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decedent’s 1978 income tax return on April

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2Id. , pp. 27-29.3Id ., p. 29.4Id ., pp.49-65.

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5, 1979, two days after the taxpayer’s death, had“constituted itself as the administrator of the estate of the

deceased at least insofar as said return is concerned.”5

Citing Basilan Estate Inc. v. Commissioner of InternalRevenue ,

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respondent argued that the legal requirement of notice with respect to tax assessments

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requires merelythat the Commissioner of Internal Revenue release, mailand send the notice of the assessment to the taxpayer atthe address stated in the return filed, but not that thetaxpayer actually receive said assessment within the five-year prescriptive period.

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Claiming that Philtrust had beenremiss in not notifying respondent of the decedent’s death,respondent therefore argued that the deficiency taxassessment had already become final, executory andincontestable, and that petitioner Estate was liabletherefor.

On September 30, 2002, the Court of Appeals rendered adecision in favor of the respondent. Althoughacknowledging that the bond of agency between Philtrustand the decedent was severed upon the latter’s death, itwas ruled that the administrator of the Estate had failed in

its legal duty to inform respondent of the decedent’s death,pursuant to Section 104 of the National Internal RevenueCode of 1977. Consequently, the BIR’s service to Philtrustof the demand letter and Notice of Assessment was bindingupon the Estate, and, upon the lapse of the statutorythirty-day period to question this claim, the assessmentbecame final, executory and incontestable. The dispositiveportion of said decision reads:

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1.

2.

“WHEREFORE, finding merit in the appeal, the appealeddecision is REVERSED AND SET ASIDE. Another one is enteredordering the Administrator of the Estate to pay the Commissionerof Internal Revenue the following:

a. The amount of P318,223.93, representing the deficiencyincome tax liability for the year 1978, plus 20% interest perannum from November 2, 1982 up to November 2, 1985 and in

addition thereto 10% surcharge on the basic tax of P169,155.34pursuant to Section 5 1 (e)(2) and (3) of the Tax Code as amendedby PD 69 and 1705; and

b. The costs of the suit.

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5Id ., p. 57.6 G.R. No. L-22492, 5 September 1967, 21 SCRA 17.7 National Internal Revenue Code of 1977, sec. 104.8 Rollo, p. 57.

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“SO ORDERED.9

Hence, the instant petition, raising the following issues:

Whether or not the Court of Appeals erred inholding that the service of deficiency taxassessment against Juliana Diez Vda. de Gabrielthrough the Philippine Trust Company was a validservice in order to bind the Estate;Whether or not the Court of Appeals erred inholding that the deficiency tax assessment and final

demand was already final, executory andincontestable.

Petitioner Estate denies that Philtrust had any legalpersonality to represent the decedent after her death. Assuch, petitioner argues that there was no proper notice of the assessment which, therefore, never became final,executory and incontestable.

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Petitioner further contendsthat respondent’s failure to file its claim against the Estate

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within the proper period prescribed by the Rules of Court isa fatal error, which forever bars its claim against theEstate.

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Respondent, on the other hand, claims that becausePhiltrust filed the decedent’s income tax return subsequentto her death, Philtrust was the de facto administrator of her Estate.

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Consequently, when the Assessment Notice

and demand letter dated November 18, 1982 were sent toPhiltrust, there was proper service on the Estate.

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Respondent further asserts that Philtrust had the legalobligation to inform petitioner of the decedent’s death,which requirement is found in Section 104 of the NIRC of 1977.

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Since Philtrust did not, respondent contends thatpetitioner Estate should not be allowed to profit from thisomission.

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Respondent further argues that Philtrust’sfailure to protest the aforementioned assessment withinthe 30-day period provided in Section

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9Id ., pp. 116-117.10 Id ., p. 19.11 Id ., p. 21.12 Id ., p. 146.13 Id.14 Id.

15 Id.

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319-A of the NIRC of 1977 meant that the assessment hadalready become final, executory and incontestable.

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The resolution of this case hinges on the legalrelationship between Philtrust and the decedent, and, byextension, between Philtrust and petitioner Estate.Subsumed under this primary issue is the sub-issue of whether or not service on Philtrust of the demand letterand Assessment Notice No. NARD-78-82-00501 was validservice on petitioner, and the issue of whether Philtrust’sinaction thereon could bind petitioner. If both sub-issues

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are answered in the affirmative, respondent’s contention asto the finality of Assessment Notice No. NARD-78-82-00501must be answered in the affirmative. This is becauseSection 319-A of the NIRC of 1977 provides a clear 30-dayperiod within which to protest an assessment. Failure tofile such a protest within said period means that theassessment ipso jure becomes final and unappealable, as a

consequence of which legal proceedings may then beinitiated for collection thereof.

We find in favor of the petitioner.The first point to be considered is that the relationship

between the decedent and Philtrust was one of agency ,which is a personal relationship between agent andprincipal. Under Article 1919 (3) of the Civil Code, death of the agent or principal automatically terminates the agency.In this instance, the death of the decedent on April 3, 1979automatically severed the legal relationship between herand Philtrust, and such could not be revived by the merefact that Philtrust continued to act as her agent when, on

April 5, 1979, it filed her Income Tax Return for the year1978.

Since the relationship between Philtrust and thedecedent was automatically severed at the moment of theTaxpayer’s death, none of Philtrust’s acts or omissionscould bind the estate of the Taxpayer. Service on Philtrustof the demand letter and Assessment Notice No. NARD-78-

82-00501 was improperly done.It must be noted that Philtrust was never appointed as

the administrator of the Estate of the decedent, and,indeed, that the court a quo twice rejected Philtrust’smotion to be thus appointed. As of November 18, 1982, thedate of the demand letter and Assessment Notice, the legalrelationship between the decedent and Philtrust hadalready been nonexistent for three years .

_______________ 16 Id ., pp. 149-150.

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Respondent claims that Section 104 of the NationalInternal Revenue Code of 1977 imposed the legal obligationon Philtrust to inform respondent of the decedent’s death.The said Section reads:

SEC. 104. Notice of death to be filed. —In all cases of transferssubject to tax or where, though exempt from tax, the gross value

of the estate exceeds three thousand pesos, the executor,administrator, or any of the legal heirs, as the case may be, withintwo months after the decedent’s death, or within a like periodafter qualifying as such executor or administrator, shall givewritten notice thereof to the Commissioner of Internal Revenue.

The foregoing provision falls in Title III, Chapter I of theNational Internal Revenue Code of 1977, or the chapter onEstate Tax, and pertains to “all cases of transfers subject totax” or where the “gross value of the estate exceeds three

thousand pesos.” It has absolutely no applicability to a casefor deficiency income tax , such as the case at bar. It furtherlacks applicability since Philtrust was never the executor,administrator of the decedent’s estate, and, as such, neverhad the legal obligation, based on the above provision, toinform respondent of her death.

Although the administrator of the estate may have beenremiss in his legal obligation to inform respondent of thedecedent’s death, the consequences thereof, as provided inSection 119 of the National Internal Revenue Code of 1977,merely refer to the imposition of certain penal sanctions onthe administrator. These do not include the indefinitetolling of the prescriptive period for making deficiency taxassessments, or the waiver of the notice requirement forsuch assessments.

Thus, as of November 18, 1982, the date of the demandletter and Assessment Notice No. NARD-78-82-00501,there was absolutely no legal obligation on the part of Philtrust to either (1) respond to the demand letter and

assessment notice, (2) inform respondent of the decedent’sdeath, or (3) inform petitioner that it had received saiddemand letter and assessment notice. This lack of legalobligation was implicitly recognized by the Court of

Appeals, which, in fact, rendered its assailed decision ongrounds of “equity.”

17

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17 Id. , p.115.

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Since there was never any valid notice of this assessment,it could not have become final, executory and incontestable,and, for failure to make the assessment within the five-year period provided in Section 318 of the NationalInternal Revenue Code of 1977, respondent’s claim againstthe petitioner Estate is barred. Said Section 18 reads:

SEC. 318. Period of limitation upon assessment and collection. —

Except as provided in the succeeding section, internal revenuetaxes shall be assessed within five years after the return wasfiled, and no proceeding in court without assessment for thecollection of such taxes shall be begun after the expiration of suchperiod. For the purpose of this section, a return filed before thelast day prescribed by law for the filing thereof shall beconsidered as filed on such last day: Provided , That this limitationshall not apply to cases already investigated prior to the approvalof this Code.

Respondent argues that an assessment is deemed made forthe purpose of giving effect to such assessment when thenotice is released, mailed or sent to the taxpayer toeffectuate the assessment, and there is no legalrequirement that the taxpayer actually receive said noticewithin the five-year period.

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It must be noted, however,that the foregoing rule requires that the notice be sent tothe taxpayer , and not merely to a disinterested party.

Although there is no specific requirement that the taxpayershould receive the notice within the said period, dueprocess requires at the very least that such notice actuallybe received. In Commissioner of Internal Revenue v. PascorRealty and Development Corporation ,

19

we had occasion tosay:

An assessment contains not only a computation of tax liabilities,but also a demand for payment within a prescribed period. It alsosignals the time when penalties and interests begin to accrueagainst the taxpayer. To enable the taxpayer to determine his

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remedies thereon, due process requires that it must be served onand received by the taxpayer.

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18 Collector of Internal Revenue v. Bautista , G.R. Nos. L-12250 & L-

12259, 27 May 1959, cited in Basilan Estates, Inc. v. Commissioner of

Internal Revenue and Court of Tax Appeals , 128 Phil. 19; 21 SCRA 17(1967).

19 368 Phil. 714; 309 SCRA 402 (1999).

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In Republic v. De la Rama ,20

we clarified that, when anestate is under administration, notice must be sent to theadministrator of the estate, since it is the saidadministrator, as representative of the estate, who has thelegal obligation to pay and discharge all debts of the estateand to perform all orders of the court. In that case, legalnotice of the assessment was sent to two heirs, neither oneof whom had any authority to represent the estate. We

said:The notice was not sent to the taxpayer for the purpose of givingeffect to the assessment, and said notice could not produce anyeffect. In the case of Bautista and Corrales Tan v. Collector of Internal Revenue . . . this Court had occasion to state that “theassessment is deemed made when the notice to this effect isreleased, mailed or sent to the taxpayer for the purpose of givingeffect to said assessment.” It appearing that the person liable forthe payment of the tax did not receive the assessment, the

assessment could not become final and executory. (Citationsomitted, emphasis supplied.)

In this case, the assessment was served not even on an heirof the Estate, but on a completely disinterested third party.This improper service was clearly not binding on thepetitioner.

By arguing that (1) the demand letter and assessmentnotice were served on Philtrust, (2) Philtrust was remiss inits obligation to respond to the demand letter and

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assessment notice, (3) Philtrust was remiss in its obligationto inform respondent of the decedent’s death, and (4) theassessment notice is therefore binding on the Estate,respondent is arguing in circles. The most crucial point tobe remembered is that Philtrust had absolutely no legalrelationship to the deceased, or to her Estate. There wastherefore no assessment served on the Estate as to the

alleged underpayment of tax. Absent this assessment, noproceedings could be initiated in court for the collection of said tax,

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and respondent’s claim for collection, filed withthe probate court only on November 22, 1984, was barredfor having been made beyond the five-year prescriptiveperiod set by law.

WHEREFORE, the petition is GRANTED. The Decisionof the Court of Appeals in CA-G.R. CV No. 09107, datedSeptember 30, 2002, is REVERSED and SET ASIDE. TheOrder of the Regional Trial Court of Manila, BranchXXXVIII, in Sp. Proc. No. R-82-

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20 124 Phil. 1493; 18 SCRA 861 (1966).21 National Internal Revenue Code of 1977, sec. 318.

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VOL. 421, JANUARY 27, 2004 277Estate of the Late Juliana Diez Vda. de Gabriel vs.

Commissioner of Internal Revenue

6994, dated November 19, 1985, which denied the claim of the Bureau of Internal Revenue against the Estate of Juliana Diez Vda. De Gabriel for the deficiency income taxof the decedent for the year 1977 in the amount of P318,223.93, is AFFIRMED.

No pronouncement as to costs.SO ORDERED.

Davide, Jr. (C.J., Chairman), Panganiban andCarpio, JJ., concur.

Azcuna, JJ., On Official Leave.

Petition granted, judgment reversed and set aside. Orderof the trial court affirmed.

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Notes. —The estate tax is one of those obligations thatmust be paid before distribution of the estate, and if notpaid, the rule requires that the distributees post a bond ormake such provisions as to meet the said tax obligation inproportion to their respective shares in the inheritance.(Estate of Hilario M. Ruiz vs. Court of Appeals , 252 SCRA 541 [1996])

The omission to file an estate tax return, and thesubsequent failure to contest or appeal the assessmentmade by the BIR is fatal, as under Section 223 of the NIRC,in case of failure to file a return, the tax may be assessed atany time within ten years after the omission, and any taxso assessed may be collected by levy upon real propertywithin three years following the assessment of the tax.(Marcos II vs. Court of Appeals , 273 SCRA 47 [1997])

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