4. Doctrines in Taxation

Doctrines in Taxation: Locus Standi and the Destination Principle

In tax litigation raising constitutional challenges, locus standi is a procedural requirement that can be relaxed when serious constitutional questions are presented and the controversy involves matters of transcendental importance, overarching significance to society, or paramount public interest¹. As held in Tayam v. Recto, G.R. No. 280898, 22 April 2026, procedural technicalities regarding legal standing must yield where the constitutionality of a tax measure directly affects the taxing power of the State, the public coffers, and the consuming public at large¹.

Substantively, the destination principle governs the imposition of value-added tax (VAT) as a tax on consumption¹. Under the destination principle, goods and services are taxed only in the country where they are consumed¹. The Court held that Republic Act No. 12079 is not unconstitutional¹.