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MARIANO LOPEZ y CHAVEZ vs . J. W.

CROW
G.R. No. 13429. October 14, 1919.

Facts:

Lorenzo Lopez declared forty or more parcels of land in the Province of Batangas
for taxation purposes where he gave the area and value of said various parcels of land.
When the area and value of said parcels of land were revised by the Treasurer of the
Province of Batangas, great discrepancies were discovered between the actual
measurement of practically every parcel of land declared by Lopez and the real actual
measurement of the same as found by virtue of said revision. J.W. Crow, the provincial
treasurer, under authority conceded to him by Act No. 2238, proceeded to collect
additional taxes for the excess area of certain lands that had been formerly declared for
assessment by their owner.

Lorenzo Lopez protested against the payment on one parcel only where the
amount so collected was but ninety-seven centavos alleging that the same was illegal,
that Act No. 2238 is void and unconstitutional, section 12 of Act No. 2238 refers solely to
real estate declared for the first time and does not apply to the area which, upon
revision, has been shown to be in excess of that which was formerly declared, that
section 12 of said Act No. 2238 has been repealed and substituted by section 2 of Act
No. 2653 which expressly declares that no land taxes should be imposed for the excess
area in the declaration of former years, inasmuch as the excess area, the tax on which
is now sought to be collected, cannot be considered as real estate declared for the first
time; and that Act No. 2653 has retroactive effect in so far as it affects this case. The
Court then ruled that said ninety-seven centavos had been legally collected, and
absolved the defendant from all liability under thecomplaint.

Issue:
Whether or not Act No. 2238 is valid and constitutional? Whether or not the
collection of additional taxes on land, the area of which was not included in former
declarations is valid?

Ruling:
Yes. Act No. 2238 is not unconstitutional and the collection, therefore, of the
taxes authorized therein are perfectly legal. Act No. 2653 has no retroactive-effect and
that its provisions amending section 12 of Act No. 2238 is a mere explanation of certain
doubts that may have existed in the text of the former law.

The State has the right inherent to its sovereignty to assess taxes upon the
property of its citizens as it is self- evident that the State needs funds to run the
Government for the benefit of its citizens, hence the existence of constitutional
provisions regulating this power of taxation. In the present case there is no ground for
maintaining that the Legislature has exceeded its powers in enacting said Act. No. 2238.
and ordering the revision of the assessments, for, indeed, the very reason that moved it
in so doing was to do justice to all, by correcting errors, so as to make all citizens pay
their respective shares proportionately to their
ability.

Act No. 2653 expressly provides that the excess area,resulting from the revision
of declared lands, must pay the corresponding tax. Section 12 of Act No. 2238 means
that all the area of the land declared must be paid for, whether included in the first
declaration or resulting from the revision, in other words, it has made more clear the
construction that should be given to the former law, Act No. 2238, which compelled
every landowner to pay for all the area of his land as for example the excess that may
be discovered in lands previously declared.
In the matter of the application of FRANK STANLEY ALLEN for a writ of habeas
corpus.
G.R. No. 1455. October 29, 1903.

Facts:
Frank Stanley Allen, who is an alien, claims that he is unlawfully detained and
restrained of his liberty in Manila, P. I., by W. Morgan Shuster, as Collector of Customs
for the Philippine Archipelago, who threatens to deport the petitioner from the Islands for
the reason that said Collector claims that the petitioner is a prohibited alien contract
laborer whose importation is forbidden by the act of Congress approved March 3, 1903,
entitled "An act to regulate the immigration of aliens into the United States."

The petitioner insists that the said Collector of Customs is without jurisdiction to
act in the premises, as he has not been authorized to execute the provisions of the law
by the Secretary of the Treasury.

Issue:
Whether or not the Act of March 3, 1903 is valid?

Ruling:

Yes. There is nothing in the act of March 3, 1903, which indicates that the
provisions it contains with respect to the exclusion of contract laborers were not to be
enforced in the Philippine Islands by the Treasury Department, through the
Commissioner-General of Immigration. If there is any inconsistency between the act of
July 1, 1902, providing for the administration of the Philippines through the War
Department and the act of March 3, 1903, the latter law must prevail. The Collector of
Customs, in the absence of officials appointed for that purpose by the Secretary of the
Treasury, has authority to enforce those provisions of the act of Congress of March 3,
1903, which restrict the immigration of aliens and contract laborers into the Philippine
Islands.

When Congress passed the immigration law, on March 3, 1903, all the existing
laws were enforced here, not under the supervision and direction of the Secretary of the
Treasury and the Commissioner-General of Immigration, but by the collectors of
customs, their inspectors and immigration officers, with the right of appeal to the Insular
Collector, under the supervision and direction of the Secretary of War and the
Commissioners of the Philippine Islands.

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