a. Lifeblood Doctrine

Tax Collection Remedies and Delinquency Requirements

Administrative remedies for tax collection, such as distraint, levy, and garnishment, cannot be wielded at will by tax authorities¹. As pronounced in CIR v. Stradcom Corporation, G.R. No. 255520, 21 April 2025, these summary collection measures may only be invoked when the taxes have already become delinquent, either through the taxpayer's admission or by virtue of a valid formal assessment adhering strictly to due process¹.

Under CIR v. Stradcom Corporation, a delinquent account refers to the amount of tax due from a taxpayer who failed to pay within the prescribed period¹. Such delinquency must arise either from a self-assessed tax or from a deficiency assessment issued by the Bureau of Internal Revenue that has become final and executory¹.