2017 Taxation Law, Q6

Heeding the pronouncement of the President that the worsening traffic condition in the metropolis was a sign of economic progress, the Congress enacted Republic Act No. 10701 (RA 10701), also known as An Act Imposing a Transport Tax on the Purchase of Private Vehicles.
Under RA 10701, buyers of private vehicles are required to pay a transport tax equivalent to 5°/o of the total purchase price per vehicle purchased. RA 10701 provides that the Land Transportation Office (LTO) shall not accept for registration any new vehicles without proof of payment of the 5% transport tax. RA 10701 further provides that existing owners of private vehicles shall be required to pay a tax equivalent to 5% of the current fair market value of every vehicle registered with the LTO. However, RA 10701 exempts owners of public utility vehicles and the Government from the coverage of the 5% transport tax.
A group of private vehicle owners sue on the ground that the law is unconstitutional for contravening the Equal Protection Clause of the Constitution.
Rule on the constitutionality and validity of RA 10701. (5%)

Quick check

What is required for a tax classification to be valid under the Equal Protection Clause?

Why does exempting public utility vehicles from a private vehicle transport tax NOT violate equal protection?

Which requirement for a valid classification ensures that a tax law applies to future vehicle buyers and owners?

What legislative power permits Congress to select which entities or transactions to tax and exempt?

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Is Republic Act No. 10701 imposing a transport tax on private vehicles constitutional?

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1. Equal Protection Test
Under the 1987 Constitution, the Equal Protection Clause does not require absolute equality in taxation nor prohibit legislative classification. A tax classification is valid if it rests on substantial distinctions, is germane to the purpose of the law, applies to both present and future conditions, and applies equally to all members belonging to the same class. Congress possesses broad discretion in selecting the subjects of taxation, and courts will uphold tax classifications unless they are shown to be manifestly arbitrary or discriminatory.

2. Substantial Distinctions Basis
Substantial distinctions exist between private motor vehicles and exempted public utility or government vehicles. Private vehicles are primarily used for personal convenience and significantly contribute to urban traffic congestion, whereas public utility vehicles provide essential public transportation services to the commuting public and government vehicles execute public administrative functions. Exempting public utilities and government vehicles from a transport tax aimed at mitigating traffic congestion rests on reasonable economic and public welfare grounds rather than arbitrary discrimination.

3. Legislative Taxation Discretion
The power of taxation is an inherent attribute of sovereignty that is inherently legislative in character. Congress enjoys wide latitude in choosing what objects, transactions, or privileges to tax and which ones to exempt from taxation. In exercising this legislative power, statutory exemptions granted to public transport operators and state instrumentalities fall well within constitutional boundaries. As long as all private vehicle owners within the designated class are taxed uniformly at the same rate, the statutory scheme satisfies constitutional equal protection requirements.

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