Francis Churchill vs James Rafferty

FACTS: The judgment appealed from in this case perpetually restrains and prohibits
the defendant and his deputies from collecting and enforcing against the plaintiffs
and their property the annual tax mentioned and described in subsection (b) of
section 100 of Act No. 2339, effective July 1, 1914, and from destroying or removing
any sign, signboard, or billboard, the property of the plaintiffs, for the sole reason
that such sign, signboard, or billboard is, or may be, offensive to the sight; and
decrees the cancellation of the bond given by the plaintiffs to secure the issuance of
the preliminary injunction granted soon after the commencement of this action.

ISSUE: Whether or not a provision in the internal revenue law prohibiting the courts
from enjoining the collection of an internal revenue tax is invalid

RULING: NO. A provision in an internal revenue law prohibiting the courts from
enjoining the collection for an internal revenue tax is not invalid as opposed to the
due process and equal protection of the law clauses of the bill of rights of the
Organic Act. Such legislation has been upheld by the United States Supreme Court

Nor is such a provision of law invalid as curtailing the jurisdiction of the courts of the
Philippine Islands as fixed by section 9 of the Organic Act; a) because jurisdiction was
never conferred upon Philippine courts to enjoin the collection of taxes imposed by
the Philippine Commission; and b) because, in the present case, another adequate
remedy has been provided by payment and protest