b. Prescriptive Period for Collection

Prescriptive Period for Collection and Due Process

Tax collection must adhere to lawful procedure and basic fairness¹. The State is duty-bound to exercise its taxing power with reasonable dispatch, as inordinate delays in resolving taxpayer protests offend due process and trigger prescription¹.

As held in CIR v. Standard Insurance Co., Inc., G.R. No. 259729, 17 November 2025, an unreasonable delay by the Bureau of Internal Revenue—such as a 13-year delay—violates due process and lawful prescriptive periods for collection, thereby justifying the cancellation of the assessment and barring the government's right to collect¹.

Moreover, issues regarding whether an assessment was issued with the requisite legal authority or due process notice are inextricably intertwined with the validity and enforceability of the assessment, and the Court of Tax Appeals may properly resolve them¹. In adjudicating these issues, courts are not restricted by the blind spots of the parties and may consider fundamental legal questions apparent from the record¹.