Philippine Health Care Providers, Inc.

vs Commissioner of Internal Revenue

FACTS
- PHCP is a domestic corporation whose primary purpose is to establish, maintain, conduct and
operate a prepaid group practice health care delivery system or a health maintenance
organization to take care of the sick and disabled persons enrolled in the health care plan and to
provide for the administrative, legal, and financial responsibilities of the organization.
- It is a prepaid health-care organization offering benefits to its members
- CIR sent a formal letter to the petitioner demanding the payment of the deficiency in the
documentary stamp tax under section 1985 of the 1997 tax code amounting to P224,702,641.18
for taxable years 1996 to 1997, including surcharges and interests
- The petitioner protested to the CIR, but it didnt act on the appeal. Hence, the company had to
go to the CTA. The latter declared judgment against them and reduced the taxes. It ordered
them to pay 22 million pesos for deficiency VAT for 1997 and 31 million deficiency VAT for 1996.

ISSUE (related to the lesson)

- Whether the court is bound by the ruling of the CA in CIR v Philippine National Bank that a
health care agreement of Philamcare Health Systems is not an insurance contract for the
purposes of the DST

HELD:
- No. Although maintained in a minute resolution, the dismissal of the petition of the cited case
was a disposition of the merits of the case. When a minute resolution denies or dismisses a
petition for failure to comply with formal and substantive requirements, the challenged
decision, together with its findings of fact and legal conclusions, are deemed sustained.
- With respect to the same subject matter and the same issues concerning the same parties, it
constitutes res judicata. However, if other parties or another subject matter (even with the
same parties and issues) is involved, the minute resolution is not binding precedent.
- there are substantial, not simply formal, distinctions between a minute resolution and a
decision.
- The constitutional requirement under the first paragraph of Section 14, Article VIII of the
Constitution that the facts and the law on which the judgment is based must be expressed
clearly and distinctly applies only to decisions, not to minute resolutions.
- A minute resolution is signed only by the clerk of court by authority of the justices, unlike a
decision. It does not require the certification of the Chief Justice. Moreover, unlike decisions,
minute resolutions are not published in the Philippine Reports.