"Eighth Issue
Petitioners next contend that tax laws are construed liberally in favor of the taxpayer and strictly against the government. This rule of construction, however, does not benefit petitioners because, as stated, there is here no room for construction since the law is clear and unambiguous.
Finally, this Court takes note of the fact that subsequent to the donations involved in this case, Congress approved REPUBLIC ACT NO. 7166 on NOVEMBER 25, 1991, providing in SECTION 13 thereof that POLITICAL/ELECTORAL CONTRIBUTIONS, DULY REPORTED to the COMMISSION ON ELECTIONS, are NOT SUBJECT TO the payment of any GIFT TAX. This all the more shows that the political contributions herein made are subject to the payment of gift taxes, since the same were made PRIOR TO the exempting legislation, and Republic Act No. 7166 provides NO RETROACTIVE EFFECT on this point.
WHEREFORE, the petition is DENIED and the assailed Decision and Resolution of the Court of Appeals are AFFIRMED.
No costs.
SO ORDERED."
G.R. No. 120721 February 23, 2005
MANUEL G. ABELLO, JOSE C. CONCEPCION, TEODORO D. REGALA, AVELINO V. CRUZ, petitioners,
vs.
COMMISSIONER OF INTERNAL REVENUE and COURT OF APPEALS, respondents.
https://lawphil.net/judjuris/juri2005/feb2005/gr_120721_2005.html