Philippine Phosphate Fertilizer Corporation ("Philphos"), a domestic, corporation registered with the Export Processing Zone Authority (EPZA), sought a refund of specific taxes paid on the purchase of petroleum products. The Commissioner of Internal Revenue (CIR) denied Philphos' 'claim for refund. On appeal, the Court of Tax Appeals (CTA) affirmed the CIR decision ratiocinating that while Philphos is exempted from the payment of excise taxes, it failed to prove its claim inasmuch as it failed to submit the invoices supporting the schedules of petroleum products. These invoices would reveal whether or not the amount claimed for refund by Philphos is correct. Appealing the CTA decision to the Supreme Court, Philphos posited that nowhere in CTA Circular No. 1- 95 is it stated that invoices are required to be pre­sented in claiming refunds. DECIDE. a. The CTA decision should be reversed consistent with the settled rule that the CTA in resolving tax cases shall not be governed strictly by technical rules of evidence.
b. The CTA decision should be set aside in line with the pronouncement of the Supreme Court that when it is disputed that a taxpayer is entitled to a refund, the State should not invoke technicalities to keep money not belonging to it. No
one, not eventhe State, should enrich oneself at the expense of another.
c. The CTA decision deserves affirmance in consonance with the oft-cited doctrine that tax refunds partake of the nature of the tax exemptions and therefore cannot be allowed unless granted in the most explicit and categorical
language.
d. The CTA decision should be sustained because Philphos failed to prove its right to such refund of taxes. The grant of refund privileges must be strictly construed against the taxpayer and liberally in favor of the government.