NITAFAN VS. COMMISSIONER OF INTERNAL REVENUE


FACTS
Petitioners, the duly appointed and qualified Judges David Nitafan, Wenceslaus Polo and Maximo Savellano, Jr. , seek to prohibit and/or perpetually enjoin respondents., the Commissioner of Internal Revenue and the Financial Officer of the Supreme Court, from making any deduction of withholding taxes from their salaries.  They submit that “any tax withheld from their emoluments or compensation as judicial officers constitutes a decrease or diminution of their salaries contrary to the provision of Section 10, Article VIII of the 1987 Constitution mandating that “during their continuance in office, their salary shall not be decreased.

ISSUE
Whether or not the imposition of taxes in the compensation of Judicial officers is contrary to the 1987 Constitution.


HELD
Yes. The clear intent of the Constitutional Commission was to delete the proposed expressed grant of exemption from payment of income tax to members of the Judiciary, so as to “give substance to equality among the three branches of Government”.  It was further expressly made clear that the salaries of members of the Judiciary would be subject to the general income tax applied to all tax payers. With the foregoing pretation, the rulling that “the imposition of income tax upon the salary of the judges is a diminution thereof, and so violates the Constitution” in Perfecto vs. Meer, as affirmed in Endencia vs. David must be declared discarded.

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