Ursal v Court of Tax AppealsG.R. Nos. L-10123 and L-10355 April 26, 1957

Facts: The petitioner is a City Assessor of Cebu and made an assessment on the real properties of Consuelo Noel and Jesusa Samson. The Latter taxpayers, on protest, brought the issue to the Cebu Board of Assessment Appeals, who reduced the valuation.

In questioning the valuation of the Cebu Board of Assessment Appeals, the petitioner took the matter to the CTA. However, the CTA dismissed the case, ruling that the petitioner, pursuant to R.A 1125 or the law creating the Court of Tax Appeals, did not have the personality to bring the matter to the CTA.

Hence, this petition.

Issue: Whether or not the petitioner has personality to file the case with the CTA?

Held: No, he does not. Under section 11 of Republic Act No. 1125 reads as follows:

SEC. 11. Who may appeal; effect of appeal. — Any person, association or corporation adversely affected by a decision or ruling of the Collector of Internal Revenue, the Collector of Customs or any provincial or city Board of Assessment Appeals may file an appeal in the Court of Tax Appeals within thirty days after the receipt of such decision or ruling.

The petitioner was not adversely affected him. At most it was the City of Cebu which was affected since they were unable to collect the higher amount of tax.

Republic Act No. 1125 creating the Court of Tax Appeals did not grant it blanket authority to decide any and all tax disputes. Defining such special court's jurisdiction, the Act necessarily limited its authority to those matters enumerated therein.