SC blocks P3.58-B tax collection vs Robinsons Convenience Stores

THE Supreme Court (SC) has ruled in favor of Robinsons Convenience Stores, Inc., dismissing a petition by the Commissioner of Internal Revenue (CIR) and barring the government from collecting P3.58 billion in alleged deficiency taxes for the 2010 taxable year.

In a decision promulgated on Aug. 27, 2025, and made public on Jan. 8, the high court’s Third Division found no grave abuse of discretion on the part of the Court of Tax Appeals (CTA), which had earlier halted the Bureau of Internal Revenue (BIR) from enforcing collection measures against the retailer.

The SC said the tax assessments were void and could no longer be enforced.

The court noted that most assessments were issued beyond the prescriptive period, and all were invalid because the revenue officers conducting the audit lacked proper authority. These defects, the SC ruled, rendered the assessments “patently illegal.”

The tax dispute traces back to a 2010 audit of Robinsons’ accounts, during which the BIR assessed the retailer for income tax, VAT, expanded withholding tax, and withholding tax on compensation, totaling P3,583,693,014.79, including surcharges and interest.

Because the assessments were void, the Supreme Court upheld the CTA’s decision to suspend tax collection without requiring Robinsons to post a bond, rejecting the CIR’s argument that a bond was mandatory.

“The Court finds no grave abuse of discretion on the part of the CTA Division,” the ruling said.

The tribunal also noted that even assuming the assessments were valid, the BIR’s right to collect through summary remedies had already expired. The warrant of distraint and levy was issued after the government’s five-year collection period had lapsed, making it void for lack of legal basis. — Erika Mae P. Sinaking