Republic of the Philippines
SUPREME COURT
Manila

EN BANC

G.R. No. L-11807             September 26, 1961

COLLECTOR OF INTERNAL REVENUE, petitioner,
vs.
CONVENTION OF PHILIPPINE BAPTIST CHURCHES and THE COURT OF TAX APPEALS, respondents.

Luis G. Hofileña and Efrain B. Treñas for respondents.
Office of the Solicitor General for petitioner.

R E S O L U T I O N


DIZON, J.:

The facts involved in this case do not show that the taxes declared refundable in our decision promulgated on January 28, 1961 were collected arbitrarily by petitioner. Therefore, resolving the motion for clarification filed by the latter, and conformably with our resolution in G.R. No. L-11976 entitled Collector of Internal Revenue vs. Antonio Prieto, et al., our resolution in this case of May 19, 1961 is clarified by extending the exemption from liability of the Collector of Internal Revenue — that is, of the Government — to the payment of interest on the refundable tax.1awphîl.nèt It is so ordered.

Bengzon, C.J., Padilla, Labrador, Concepcion, Reyes, J.B.L., Paredes and De Leon, JJ., concur.


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