GR L 6961; (June, 1955) (Digest)
G.R. No. L-6961; June 17, 1955
FELIX CALALANG, petitioner-appellee, vs. PABLO LORENZO and PRIMO VILLAR, respondents-appellants.
FACTS
The petitioner, Felix Calalang, commenced an action in the Court of First Instance of Manila to compel the Secretary of Public Works and Communications (Pablo Lorenzo) and the Chief of the Motor Vehicles Office (Primo Villar) to authorize the payment of his motor vehicle registration fees for the year 1953 using a backpay certificate of indebtedness. The respondents contended that such fees are not taxes and, therefore, not authorized for payment with the certificate. The trial court ruled in favor of Calalang, prompting the respondents to appeal.
ISSUE
Whether motor vehicle registration fees, as prescribed by the Revised Motor Vehicle Law, come within the purview of the Backpay Law (Republic Act 304, as amended) as “taxes” that may be paid using a backpay certificate of indebtedness.
RULING
Yes. The Supreme Court affirmed the trial court’s decision, holding that motor vehicle registration fees are taxes and may be paid with a backpay certificate of indebtedness. The Court ruled that the appellation “fees” is not determinative; the object of the charge is. Taxes are generally for revenue, while fees are for regulation and inspection, limited to the cost of services rendered. The Court found that the expenditures of the Motor Vehicle Office constituted only about five percent of the total collections from these fees, and the law provided that all such money shall accrue to funds for the construction and maintenance of public roads, streets, and bridges. This demonstrates that the exaction is primarily for revenue to support a governmental function, making it a veritable tax. Furthermore, the Revised Motor Vehicle Law itself, particularly Section 70(b) as amended by Republic Act 587, which states that “no other taxes or fees than those prescribed in this Act shall be imposed,” implies that the charges imposed, though called fees, are of the category of taxes. The Court also noted commentaries and a ruling from the Auditor General supporting the classification of these fees as taxes for the purposes of the Backpay Law.