Finals in Taxation Law Review

Atty. Richard M. Fulleros, CPA, MBA

Problem 1

A Corporation is a non-vat registered entity. For the first quarter of the calendar year, their
sales ballooned to 2M
a. Is A corporation required to register for VAT? 4 pts.
No, under the train law the minimum threshold for registration of vat is 3 Million.

b. Suppose that the facts of the case occurred in 2016, how much is the VAT threshold?
3 pts.
1919500

c. Suppose that the facts of the case occurred in 2018, are the sales of the Corporation
subject to VAT? 3pts.
No, because the total sales for the first quarter did not reach the minimum threshold.
He is only liable upon reaching the 3 million threshold, upon which he will be
required to pay vat.
Problem 2

Madam X owns real property in Caloocan City. On July 1, 2014, she received a notice of
assessment from the City Assessor, informing her of a deficiency tax on her property. She
wants to contest the assessment.

(A) What are the administrative remedies available to Madam X in order to

contest the assessment and their respective prescriptive periods? 5 points

- Filing of protest against the assessment

- The protest on the assessment may either be a request for

reconsideration or a request for reinvestigation. The difference
between the two is that in a request for reconsideration, the
correctness of the assessment will be reviewed based on existing
records only, while in a request for reinvestigation, the assessment
will be reviewed based on both existing documents and additional
evidence that the taxpayer intends to submit to the BIR.

- Within 30 days from receipt of the FAN, the taxpayer must file a
protest before the BIR to dispute the FAN. The BIR shall then have
180 days within which to decide on the matter. If the protest is in
the nature of a request for reconsideration, the 180-day period shall
be reckoned from the day the protest has been filed. However, if
the protest is in the nature of a request for reinvestigation, the 180-
day period shall be reckoned on the day the last submission of
 documents or receipts, which the taxpayer is required to submit
within 60 days from filing of the protest [Sec. 228, Supra].

(B) May Madam X refuse to pay the deficiency tax assessment during the
pendency of her appeal? 5 points

- In such instances where the assessment has already become final

and executory, the taxpayer will be obliged to pay for the amount
of taxes as assessed by the BIR. But if the taxpayer has no capacity
to pay the assessed amount, the taxpayer still has another remedy
that he may avail of, and that is, to enter into a compromise with
the BIR.

Problem 3

A VAT registered taxpayer made the following sales:

Sales destination Terms Payment

China FOB Destination USD 10,000
Malaysia FOB Destination P450,000
Hongkong FOB Shipping point Yen 800,000
Philippines FOB Shipping point P300,000

How much is the foreign currency denominated sales? (suppose the exchange rate of USD to
peso is 42 per USD and yen to peso is P0.50 to 1 Yen.?

- 2. Foreign currency denominated sale – the sale to a non-resident

of goods assembled or manufactured in the Philippines for delivery
to a resident in the Philippines paid in acceptable foreign currency
and accounted for in accordance with BSP rules and regulations

How much is the zero – rated sales?

- A VAT zero-rated transaction are sales by VAT-registered persons

which are subject to 0% rate, meaning the tax burden is not passed
on to the purchaser. A zero-rated sale by a VAT-registered person,
which is a taxable transaction for VAT purposes, shall not result in
any output tax. However, the input tax on his purchases of goods,
properties or services related to such zero-rated sale shall be
available as tax credit or refund.
- Enumerate the zero-rated sales of goods.
- 1. Export Sales (IF GONE)
o a) Sale and actual shipment of goods from the Philippines
to a Foreign country
 o b) Sale of raw materials or packaging materials to a Non-
resident buyer for delivery to a resident local export-
oriented enterprise
o c) Sale of raw materials or packaging materials to Export-
oriented enterprise whose export sales exceed 70% of total
annual production
o d) Sale of Gold to the BSP
o e) Those that are not considered export sales under the
Omnibus Investment Code and other special laws
o f) Sale of goods, supplies, and equipment and fuel to
persons engaged in International shipping or international
air transport operations.
- 2. Foreign currency denominated sale – the sale to a non-resident
of goods assembled or manufactured in the Philippines for delivery
to a resident in the Philippines paid in acceptable foreign currency
and accounted for in accordance with BSP rules and regulations
- 3. Sales to persons or entities whose exemption under special laws
and international agreements to which the Philippines is a signatory
subjects such sales to 0% rate (effectively zero-rated transactions)

Problem 4

Phil-Air is a domestic air carrier with both domestic and international operations. During the
month, it had the following gross receipts:

Domestic operations
Transport of passengers P40,000,000
Transport of cargoes 12,000,000

International operations
Transport of passengers 30,000,000
Transport of cargoes 20,000.000

Are all the gross receipts of Phil-Air subject to VAT? Why?

- A Value-Added Tax is a tax assessed, levied, and collected on every

importation of goods,
- whether or not in the course of trade or business,
- or imposed on each sale, barter, exchange or lease of goods or
properties
- or on each rendition of services in the course of trade or business as
they pass along the production and distribution chain,
- the tax being limited only to the value added to such goods,
properties or services by the seller, transferor or lessor.

How much of the gross receipts of Phil-Air is subject to VAT?

 - Gross receipts means the total amount of money or its equivalent
representing the contract price, compensation, service fee, rental or
royalty actually or constructively received during the taxable
quarter for the services performed or to be performed for another
person.

Compute for the Output VAT of Phil-Air?

- Hence, "output tax" is the value-added tax on the sale of taxable

goods or services by any person registered or required to register
under the Tax Code.

- Otherwise stated, output tax is the VAT due on the sale or lease or
taxable goods, properties or services by an VAT-registered person.
On the
- other hand, input tax is the VAT due on or paid by a VAT-registered
person on importation of good or local purchases of goods or
services, including lease or use of properties, in the course of his
trade or business.

 Vat Payable = Output Tax – Input Tax

 Okay example. Let’s say seller ka ng wooden furniture. Anong
kailangan mo para makagawa ka ng produkto mo? Eh di kahoy.
Wooden furniture nga diba. So bumili ka ng kahoy. Yung nagbenta
sa iyo binigyan ka ng invoice. Pagtingin mo sa invoice mo naka-
indicate yung 12% VAT na binayaran mo sa pagbili mo ng kahoy.
Yan ang input tax mo! So using the kahoy, you made let’s say
tables and chairs. Eh since ibebenta mo ito, subject ka sa VAT.
Tawag mo dyan output tax. Under the Tax Credit Method, puwede
mo ibawas ang 12% na binayaran mo sa pagbili ng kahoy doon sa
babayaran mo na 12%VAT sa pagbenta mo ng final product mo,
yung tables and chairs. Because of that nabawasan mo ang VAT
liability mo.

Formula (gross receipts subject to VAT/1.12)

Problem 5

Attorney B is a self employed professional (SEP) whose annual earnings from cases handled
is P2,900,000.00.

a. Is Attorney B required to pay VAT? Why? 2 points

 - No. RR 7-2004 [MAY 7, 2004] excludes services by doctors
registered with the PRC and services by lawyers registered with the
IBP as well as GPPs for the sole and exclusive purport of practising
law or medicine from the coverage of VAT on services

b. Is Attorney B required to pay percentage tax? Why? 2 points

- Percentage Tax

- For small businesses with gross annual sales and receipts that do
not exceed Php1,919,500.00, and are not VAT-registered,
percentage tax is imposed for sold or leased goods, properties or
services. The tax rate varies depending on the nature of business.
The usual rate is 3% but it could go as high as 30%, for gross
receipts of Jai-Alai and racetrack operators for instance.

- Who Are Required to File Percentage Tax?

o 1. Any person exempted from VAT under Sec. 109z of the

Tax Code.

o 2. Domestic carriers and keepers of garages.

o 3. International air and shipping carriers based in the

country.

o 4. Franchise grantees of utilities.

o 5. Franchise grantees in broadcasting business the annual

gross receipts of which do not exceed Php10M and opted
not to register as VAT taxpayers.

o 6. Operators of communications equipment sending

dispatch, messages, or conversations overseas.

o 7. Life insurance premiums and agents of foreign insurance

companies.

o 8. Proprietor, lessee, or operator of betting businesses such

as cockpits, race tracks, cabarets, etc.

o 9. Stock brokers trading through Local Stock Exchange

other than sake of dealer in securities, as well as corporate
issuers or stock brokers of domestic or foreign markets.

c. If Attorney B pays both the VAT and income tax, is this not a clear case of double
taxation? Explain. 4 points
 - No

- DOUBLE TAXATION DEFINED

o When the same taxable item is taxed more than once1 by

o either the same or by different government agencies,2 there

o is said to be double taxation

- Income Tax is a tax on a person's income, emoluments, profits

arising from property, practice of profession, conduct of trade or
business or on the pertinent items of gross income specified in the
Tax Code of 1997 (Tax Code), as amended, less the deductions if
any, authorized for such types of income, by the Tax Code, as
amended, or other special laws.

- Define VAT here

d. Suppose Attorney B is earning only P500,000.00 yearly, what is his tax liability under
the TRAIN law? 2 points

Problem 6

A Corporation is a domestic corporation whose annual sales is P5,000,000.00. The BIR

issued a letter of authority (LA) to conduct an audit of the 2017 income tax return and all
related years.

a. Is the LA valid? Why?

- 1. When does the audit process begin? The audit process

commences with the issuance of a Letter of Authority to a taxpayer
who has been selected for audit.

- 2. What is a Letter of Authority? The Letter of Authority is an

official document that empowers a Revenue Officer to examine and
scrutinize a Taxpayer's books of accounts and other accounting
records, in order to determine the Taxpayer's correct internal
revenue tax liabilities.
 - 3. Who issues the Letter of Authority? Letter of Authority, for
audit/investigation of taxpayers under the jurisdiction of National
Office, shall be issued and approved by the Commissioner of
Internal Revenue, while, for taxpayers under the jurisdiction of
Regional Offices, it shall be issued by the Regional Director.

- 4. When must a Letter of Authority be served? A Letter of

Authority must be served to the concerned Taxpayer within thirty
(30) days from itsBe Smart Don’t Get Caught date of issuance,
otherwise, it shall become null and void. The Taxpayer shall then
have the right to refuse the service of this LA, unless the LA is
revalidated.

- 5. How often can a Letter of Authority be revalidated? A Letter of

Authority is revalidated through the issuance of a new LA.
However, a Letter of Authority can be revalidated.

- Only once, for LAs issued in the Revenue Regional Offices or the
Revenue District Offices; or Twice, in the case of LAs issued by
the National Office.

- Any suspended LA(s) must be attached to the new LA issued

(RMO 38-88).

b. What do you mean by implied assessment? Is it valid?

Problem 7

C Corporation is manufacturing and selling various products. The BIR suspects that C
Corporation is involved in illegal activities, so one day, it forcefully opened the door of the
warehouse of C Corporation and found smuggled goods and assessed them with the proper
tax.

a. Is the assessment valid? Why? 4 points

- The term assessment may refer to:

o 1. The official action of an administrative officer in

determining the amount of tax due from a taxpayer

o 2. A notice to the effect that the amount therein stated is due

from the taxpayer as a tax with a demand for payment of
the tax or deficiency stated therein.

- What are the requisites of a valid assessment?

 o 1. A formal letter of demand and assessment notice shall be
issued by the CIR or his duly authorized representative

o 2. The letter of demand calling for payment of the

taxpayer’s deficiency tax or taxes shall state the facts, the
law, rules and regulations or jurisprudence on which the
assessment is based. Otherwise, the formal letter of demand
and assessment notice shall be void

o 3. The same shall be sent to the taxpayer only be registered

mail or by personal delivery

o 4. If sent by personal delivery, the taxpayer or his duly

authorized representative shall acknowledge receipt thereof
in duplicate copy of the letter of demand, showing the
following:

 i. His name

 ii. Signature

 iii. Designation and authority to act for and in behalf

of the taxpayer, if acknowledge received by a person
other than the taxpayer himself; and

 iv. Date of receipt thereof (see Section 3.1.4, RR

No. 12-99)

b. Suppose that the BIR already had prior request for the production of documents to C
Corporation and the same had been ignored time and again, will the assessment be
valid?

Problem 8

Explain the TAX remedies of the government in 200 words (10 points)

REMEDIES AVAILABLE TO THE GOVERNMENT IN THE COLLECTION OF THE INCOME TAX...VERY

IMPT!!

1. ADMINISTRATIVE
a. Distraint of personal property;
b. Levy of personal property
c. Enforcement of forfeiture of property
d. Enforcement of tax lien
e. Requiring the filing of bonds
f. Requiring proof of filing income tax returns
g. Deportation of aliens
h. Inspection of books of accounts.

2. JUDICIAL
a. ordinary civil action
b. criminal action

DISTRAINT- seizure by the government of personal property, tangible or intangible, to enforce the
payment of taxes to be followed by its public sale if the taxes are not voluntarily paid.

Kinds of Distraint
a. Actual- there is taking of possession of the personal property out of the taxpayer into that of the
government;
b. Constructive- the owner is merely prohibited from disposing of his property.

LEVY- A summary administrative remedy, seizure of real property to enforce payment of taxes.

A written notice of levy, containing a description of the property upon which levy is made, the
name of the taxpayer and the amounts of the tax and penalty due from them is served upon the
taxpayer.

FORFEITURE- a divestiture of property without compensation, in consequence of a default or

offense. In case of chattels and removal of fixtures of any sort, forfeiture is enforced by seizure
and sale or destruction of the specific forfeited property. The forfeiture of real property is
enforced by a judgment of condemnation and sale in a legal action or proceeding, civil or criminal,
as the case may require.

TAX LIEN- a legal claim or charge on property either real or personal established by law as a
security in default of the payment of taxes. The tax, together with interest, penalties and cost that
may accrue in addition thereto is a lien upon all property and rights to property belonging to the
taxpayer. The lien however, shall not be valid against any mortgagee, purchaser or judgment
creditor until legal notice of such liens should be filed by the Commissioner of internal revenue in
the Office of the Register of Deeds of the province or city where the property of the taxpayer is
located. The lien attaches when the taxpayer neglects or refuses to pay the tax after demand, but
relates back from the time when assessment was made by the Commissioner.

REQUIRING THE FILING OF BONDS- Filing of performance bond to secure the payment of taxes
or compliance with certain provisions of tax laws and regulations. This may be required by the BIR
for the issuance of a tax clearance.

REQUIRING PROOF OF FILING INCOME TAX RETURNS. – Before a license to engage in trade or
business or occupation or to practice a profession can be issued to a person, partnership,
association or corporation, he must submit to the officer issuing such license or permit, proof that
he has filed his income tax return during the preceding year and that income taxes due have been
paid thereon.

DEPORTATION OF ALIENS- any alien who

1. knowingly and fraudulently evades the payment of any internal revenue tax or
2. willfully refuses to pay such tax and its accessory penalties after the decision on the tax liability
rendered by the Commissioner of Internal Revenue, or the CTA or any competent judicial tribunal
shall have become final and executor, is subject to deportation. The penalty of deportation is not a
bar to any proceeding taken by the government to enforce collection of tax delinquency.

INSPECTION OF BOOKS OF ACCOUNTS

JUDICIAL ACTION
1. Civil Action- After the assessment made by the Commissioner of Internal Revenue has become final
and executory for failure of the taxpayer to dispute the same and appeal the disputed assessment to the
Court of Tax Appeals, the government may institute civil actions to collect internal revenue taxes in the
Regional Trial Court and the Metropolitan Trial Court, City and municipal courts.
 2. Criminal Action- maybe pursued by the authorities for the collection of delinquent taxes. An
assessment of a tax deficiency is not necessary to a criminal prosecution for tax evasion. The crime is
complete when the violator has knowingly and willfully filed a fraudulent return or neglected to file a
return with intent to evade the tax. If the taxpayer is acquitted, the government may still collect the tax
in a civil action, because the payment of a tax is an obligation imposed by statute and does not arise
from a criminal act.

Prescriptive period for collection.

Where an assessment was made, the period for collection by judicial action or by distraint or levy is
within 3 years after the date of assessment. Where no assessment was made and a return was filed, and
the same is not false or fraudulent, the period for collection by a proceeding in court is within 3 years
after the return was due or filed whichever is later, except:

Where a return required to be filed was not filed, or even if filed the same is false or fraudulent, and
made with the intent to evade the tax, the period is ten years after discovery of the omission to file the
return or from the discovery of the falsity or fraud. The other exception relative to the prescriptive
periods for assessment are also applicable.

Where the government makes another assessment on the basis of a reinvestigation requested by the
taxpayer, or a revised assessment because of an amended return or as a result of a reinvestigation
asked for by the taxpayer, the period is counted from the last assessment or the last revised
assessment.

Where the action is brought to enforce a compromise agreement into between the commissioner and the
taxpayer, the prescriptive period is ten years from the time the cause of action accrues as fixed in the
civil code.

The running of the statute of limitation on the making of an assessment, the beginning of
distraint or levy or any proceeding in court for collection is suspended: IMPT!!!!!

1. for the period during which the Commissioner of Internal Revenue is prohibited from making tax
assessment or beginning the distraint or levy or any proceeding in court and for sixty days thereafter;

2. when the taxpayer requests for a reinvestigation which is granted by the commissioner;

3. when the taxpayer cannot be located in the address given by him in the return filed upon which a tax
is being assessed or collected, unless the taxpayer informs the Commissioner of any change in address;

4. when the warrant of distraint and levy is duly served upon the taxpayer, his authorized
representative, or with a member of his household with sufficient discretion and no property could be
located; and

5. When the taxpayer is out of the Philippines.

Explain the TAX remedies of the taxpayer in 300 words (10 points)

REMEDIES OF THE TAXPAYER

BEFORE PAYMENT

1. administrative protest
2. request for reconsideration
3. request for reinvestigation
4. judicial protest

AFTER PAYMENT

1. claim for tax refund

2. claim for tax credit

1. Administrative Protest (Protest against Assessment)

WHEN: within 30 days from receipt of final assessment notice (FAN)

WHERE: BIR

HOW: written protest, stating facts, applicable law, rules and

regulations or jurisprudence o which his protest is based; if only
portions of FAN are disputed, must pay the deficiency tax on
undisputed portion

PROCEDURE:

1. protest against pre-assessment notice (PAN) within 15 days

from receipt
2. protest against FAN within 30 days from receipt
3. submit relevant documents within 60 days from filing of
protest
4. CIR has 180 days to decide
5. in case of denial or lapse of 180-day period, taxpayer has 30
days to bring his protest to the CTA en division

WHEN PAN IS NOT REQUIRED:

1. finding for any deficiency tax is the result of mathematical

error in computation of tax as appearing on face of return
2. a discrepancy has been determined between the tax withheld
and the amount actually remitted
3. taxpayer who opted to claim a refund or credit of excess
creditable withholding tax for at taxable period was determined to
have carried over and automatically applied the same amount
 claimed against the estimated tax liabilities for the taxable
quarter/s for the succeeding taxable year/s
4. excise tax due on excisable articles have not been paid
5. article locally purchased or imported by an exempt person

2. Request for Reconsideration – a plea for re-evaluation of an

assessment on the basis of EXISTING RECORDS without need of
additional evidence (question of law or fact or both)

3. Request for Reinvestigation – a plea for reinvestigation of an

assessment on the basis of NEWLY-DISCOVERED EVIDENCE that a
taxpayer intends to present in the reinvestigation (question of law or
fact or both)

- in either case, the request must be accompanied by a WAIVER of

the statute of limitations in favor of the government

4. Judicial Protest

PROCEDURE

1. within 30 days from denial of protest by CIR or from lapse of

180-day period, appeal to CTA division
2. if CTA division denies, motion for reconsideration within 15
days from receipt
3. within 15 days from denial of motion, appeal to CTA en banc
4. appeal to SC within 15 days by petition for review (Rule 45)

5. Refund/Credit
- based on the legal principle of quasi-contract or solutio indebiti
- in the nature of an exemption, which cannot be allowed unless
granted in the most explicit and categorical language
- strictly construed against the claimant (proof of claim must be
established)
- partial payment of a tax cannot be the basis for a tax refund
- interest on taxes refunded may not be paid by the Government to
the taxpayer, UNLESS: (a) the CIR acted with patent arbitrariness
(inexcusable or obstinate disregard for legal provision); and (b) in
the case of income taxes withheld on the wages of employees,
which must be refunded within 3 mos from April 15

Tax Refund vs. Tax Credit

o R: takes place when there is actually a reimbursement of the
tax
o C: the Government issues a tax certificate or tax credit memo
covering the amount determined to be reimbursable, which can be
applied after proper verification against any sum that may be due
and collectible from the taxpayer

Requisites for Recovery

1. there was an actual collection and receipt by the Government

of the tax sought to be recovered (factual proof)
2. legal basis for the granting of refund or credit, including
verification of compliance with the statutory requirements relative
to the filing of claims within the reglementary 2-yr period
3. in case of corporations, must signify whether to avail of tax
refund or tax credit in the corporate income tax return

Filing of protest against the assessment

The protest on the assessment may either be a request for
reconsideration or a request for reinvestigation. The difference between
the two is that in a request for reconsideration, the correctness of the
assessment will be reviewed based on existing records only, while in a
request for reinvestigation, the assessment will be reviewed based on
both existing documents and additional evidence that the taxpayer
intends to submit to the BIR.

Within 30 days from receipt of the FAN, the taxpayer must file a protest
before the BIR to dispute the FAN. The BIR shall then have 180 days within
which to decide on the matter. If the protest is in the nature of a request
for reconsideration, the 180-day period shall be reckoned from the day the
protest has been filed. However, if the protest is in the nature of a request
for reinvestigation, the 180-day period shall be reckoned on the day the
last submission of documents or receipts, which the taxpayer is required
to submit within 60 days from filing of the protest [Sec. 228, Supra].
Appeal to the Court of Tax Appeals (“CTA”)
If the protest is denied by the BIR, in whole or in part, or the 180-day
period has already lapsed without the BIR acting upon the protest, the
taxpayer may appeal the denial to the CTA within 30 days form the receipt
of the denial, or from the lapse of the 180-day period to decide.
1. After appealing to the CTA, and after rendering an unfavorable
decision, taxpayer may file a motion for reconsideration of said
 decision within 15 days from receipt of the decision of the CTA
sitting in division.
2. If the decision is still unfavorable, the taxpayer may appeal to the
CTA en banc [See: R.A. No. 9282].
Appeal to the Supreme Court
If the CTA en banc still renders an unfavorable decision, the taxpayer still
has the remedy to file a petition for certiorari before the Supreme Court,
only on the ground of grave abuse of discretion amounting to lack or
excess of jurisdiction. Jurisprudence describes grave abuse of discretion as
referring to the capricious or whimsical exercise of judgment as is
equivalent to lack of jurisdiction. The abuse of discretion must be patent
and gross as to amount to an evasion of a positive duty or a virtual refusal
to perform a duty enjoined by law, or to act at all in contemplation of law,
as where the power is exercised in an arbitrary and despotic manner by
reason of passion and hostility [See: G.R. No. 172832].
Action for collection of taxes
Once the assessment has become final, a civil action for collection of
taxes may be instituted by the government against the taxpayer before
the following courts:

1. Municipal Trial Court – For claims not exceeding Php 300,000.00

(outside Metro Manila), or not exceeding Php 400,000.00 (within
Metro Manila)
2. Regional Trial Court – For claims exceeding Php 300,000.00 (outside
Metro Manila), or exceeding Php 400,000.00 (within Metro Manila),
provided that the amount to be collected is less than Php
1,000,000.00.
3. Court of Tax Appeals – For claims amounting to Php 1,000,000.00
and above.
The decision of the Municipal Trial Court sustaining an undisputed
assessment would be appealable to the Regional Trial Court. Such decision
of the Regional Trial Court would be appealable to the Court of Tax
Appeals, and ultimately to the Supreme Court, in accordance with the
provisions of the Rules of Court. Any decision of the CTA upon the tax
collection may be appealed to the Supreme Court through a verified
petition for review on certiorari.

Tax compromise
In such instances where the assessment has already become final and
executory, the taxpayer will be obliged to pay for the amount of taxes as
assessed by the BIR. But if the taxpayer has no capacity to pay the
assessed amount, the taxpayer still has another remedy that he may avail
of, and that is, to enter into a compromise with the BIR.
If the compromise is based on financial incapacity to pay the tax, the
taxpayer will be required to settle only as low as 10% of the basic tax due.
The taxpayer may also opt to compromise based on doubtful validity of
the assessment, but the amount to be settled can be as low as 40% of the
basic tax due [See: Sec. 204(A), NIRC].
Given the foregoing, it is therefore clear that there are remedies available
for a taxpayer to avail in every stage of the assessment and collection
process. This does not mean, however, that these remedies may be
abused and misused just to evade payment of correct taxes, or even just
to delay the process. There is still no substitute to making the necessary
tax payments when payment is indeed due. After all, taxes are the
lifeblood of the government, without which, the State cannot fulfill its
mandate of promoting the general welfare and well being of the
people [See: G.R. No. 159796].

God bless you.