Following my recent article about Puerto Princesa’s troubling pattern of anti-taxpayer policies, many readers have asked for a simpler breakdown of the City Treasurer’s official response. I have a copy of the letter denying a taxpayer’s protest against Sunday deadline penalties.
The redacted version of the City Treasurer’s reply may be found here:
https://drive.google.com/file/d/1iTNM7-wqU5o9MMz1Wz1r9b7GYPQA9qDb/view?usp=drive_link
(Note on Authorship: The letter denying the refund for penalties, while signed and issued under the name of the City Treasurer, was reportedly drafted by another individual within the office. Nevertheless, as the Treasurer’s signature appears on the document, it constitutes the official position of the City Treasurer’s Office for all legal and administrative purposes.)
For ready reference, you may also find copy of the City Revenue Code here:
https://docs.google.com/document/d/15vgboOWWtinxu1P691WmYMZKdIIz64H_/edit?usp=drive_link&ouid=103911894325864192844&rtpof=true&sd=true
While the response aims to sound official and legally solid, its arguments quickly fall apart under scrutiny. It’s crucial for the public to understand what’s truly being said and why it doesn’t make sense. Let’s analyze the arguments in detail.
Argument #1: “The Rule Doesn’t Apply Because It Would Be Absurd”
The City Treasurer writes: “The beginning of the section provides that the rule on computation of time shall be observed, however it also provides for qualifier ‘unless inconsistent with the manifest intent of the provisions’ and ‘or when applied they would lead to absurd or highly improbable results’.”
He continues: “Further, even if the words seem clear, if applying them literally would result in illogical or unreasonable consequences or things that clearly weren’t meant to happen, hence it should be avoided in favor of a more reasonable interpretation.”
Think about this for a moment. Is it “absurd” or “illogical” to let someone pay their taxes on Monday when the deadline falls on Sunday? Don’t banks do this all the time with loan payments? BIR and other national government offices follow this same rule in their own laws.
What is absurd is to expect people to pay taxes on a day when government offices are traditionally closed! Is the City Treasurer truly applying the “absurd results” clause because the outcome is unreasonable, or simply as an excuse to disregard a rule he dislikes?
Argument #2: “Business Tax Rules Override General Rules”
The City Treasurer’s position hinges on Section 1B.03(e) of the Revenue Code, which states: “If the provisions of different chapters conflict with each other, the provisions of each chapter shall prevail as to all specific matter and questions involved therein.”
Based on this, he argues: “Reliance on Section 1B.03(c) [the computation rule, Chapter 1] is untenable… the provisions under Section 3A.03 [deadlines, Chapter III] pertaining to Business Tax and Other Taxes, shall prevail.”
But here’s the critical question: Is there really an actual conflict between Chapter III’s deadline provisions and Chapter I’s computation rule? None!
• Chapter III (Business Tax) explicitly sets April 20 as the quarterly deadline but says nothing about what happens when that date falls on a Sunday.
• Chapter I (General Provisions) fills this gap with Section 1B.03(c): “When the last day falls on a Sunday or Holiday… the next business day shall be considered the last day.”
These provisions complement, not contradict, each other. Chapter III establishes when taxes are due (April 20), while Chapter I explains how to calculate that deadline when practical realities (like Sundays) interfere.
This is like a traffic law that sets a speed limit of 60 km/h (specific rule) and another law requiring drivers to adjust speed during heavy rain (general safety rule). These don’t conflict—they work together to ensure safe driving under different conditions.
The City Treasurer’s interpretation would nullify the computation rule for all fixed deadlines, rendering it meaningless. If every chapter had to repeat the computation rule to apply it, the Code would be cluttered with redundant language. The general rule exists precisely to avoid this inefficiency.
By falsely claiming a conflict, the City Treasurer ignores the PPC Revenue Code’s design: specific rules set deadlines, general rules ensure fairness when practical realities get in the way.
Argument #3: “Any Extension Needs a Special Law”
The City Treasurer states: “The provision in question is clear and unequivocal with respect to the deadlines prescribed therein. It is evident from the language of the Ordinance that it was the deliberate intent of the Sangguniang Panglungsod to fix the deadline for the payment of business taxes for the second quarter on April 20.”
He adds: “The same section further provides that any extension of the period for payment of taxes without the imposition of penalties or surcharges may only be effected through a duly enacted ordinance.”
This shows the City Treasurer doesn’t understand the difference between two completely different things. Extending a tax period means changing when taxes are due – like moving the deadline from April to May. Computing time means figuring out the actual last day when a fixed deadline falls on a weekend or holiday.
If your boss says, “finish this report by Friday” and Friday turns out to be a holiday, letting you submit it on Monday isn’t extending the deadline – it’s just common sense about when you can turn in the work.
Argument #4: “We’re Open on Weekends, So You Have No Excuse”
The City Treasurer emphasizes: “It is the established practice of this office to remain open and accessible to serve our taxpayers whenever a deadline coincides with a Saturday, Sunday, or a public holiday.”
He continues: “Additionally, online payment facilities have been implemented to facilitate the timely discharge of tax obligations by our clients, regardless of their location or the time of day. The option of making tax payments via online methods is not new to your corporation.”
This argument completely misses the point. Just because the government chooses to provide extra services doesn’t mean they can take away legal protections that are already written into law. Taxpayers have the right to rely on what the law says, not on whether the government happens to be feeling helpful on weekends or Holidays when offices are closed.
Plus, many taxpayers don’t even know about these extra services. Should people be penalized for not following City Treasury Office’s Facebook posts about special weekend procedures when the law already protects them?
The Real Problem: Choosing Government Over Taxpayers Every Time
Throughout the letter, whenever the City Treasurer must choose between an interpretation that helps taxpayers or one that helps government penalty imposition, he consistently chooses the latter. This violates a basic principle of fair taxation: when tax laws can be read different ways, the reading that helps taxpayers should win.
The Bottom Line
The Treasurer’s conclusion states: “In view of the foregoing and upon due consideration of the facts and applicable provisions, the petition for the immediate cancellation of the assessed penalty and the corresponding request for tax refund or tax credit is hereby DENIED.”
This denial is based on arguments that basically boil down to: “We don’t want to follow this rule because it might cost us penalty money, so we’re going to find reasons to ignore it.”
They’re taking a clear, simple rule – “when deadlines fall on Sunday, you get until Monday” – and twisting it into something complicated so they can avoid following it. This isn’t good faith interpretation of the law; it’s creative excuse-making.
Why This Matters and What You Can Do
If you paid your business taxes on April 21, 2025, and received a penalty, don’t be discouraged by the denial letter—its arguments are weak and may not hold up in court.
Your Options:
• Step 1: Appeal to the City Mayor. Submit a Motion for Reconsideration, highlight the legal errors, and request the Mayor instruct the Treasurer to follow Section 1B.03(c). The Mayor may be open to a fairer interpretation that supports local businesses.
• Step 2: If your appeal is denied or ignored, consider taking the matter to court. The City Treasurer’s reasoning is questionable and could be overturned. Consult a tax lawyer to assess your case.
This issue goes beyond individual penalties—it’s about ensuring Puerto Princesa upholds the rule of law and treats taxpayers fairly. By standing up, you help protect the rights of the entire business community.
“Disclaimer: The content presented here reflects my own interpretation and does not constitute legal advice. I am not a lawyer. I encourage readers to seek independent legal counsel for any legal matters.
