18. Central-Azucarera-Don-Pedro-vs-CTA.docx - Central...

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Central Azucarera Don Pedro v. CTA G.R. Nos. L-23236 and L-23254, May 31, 1967 DOCTRINE: The doctrine of unconstitutionality raised by appellant is based on the prohibition against ex post facto laws. But this prohibition applies only to criminal or penal matters, and not to laws which concern civil matters or proceedings generally, or which affect or regulate civil or private rights. FACTS: Central Azucarera Don Pedro, a domestic corporation with office at Nasugbu, Batangas, had been filing its income tax returns on the "fiscal year" basis ending August 31, of every year. It had been assessed deficiency tax plus interest. It paid the deficiency tax but protested on the imposition of the interest], claiming that the imposition of ½% monthly interest on its deficiency tax for the fiscal year 1954 to 1958, Pursuant to Section 51 (d) of the Revenue Code, as amended by Republic Act No. 2343, is illegal, because the imposition of interest on efficiency income tax earned prior to the effectivity of the amendatory law (Rep. Act 2343) [on 1959] will be tantamount to giving it (Rep. Act No. 2343)

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