Cezar Salarza & Partners Law Offices

21/05/2026

𝗕𝗜𝗥 𝗟𝗔𝗨𝗡𝗖𝗛𝗘𝗦 “𝗘𝗔𝗦𝗘 𝗢𝗙 𝗖𝗟𝗢𝗦𝗜𝗡𝗚 𝗕𝗨𝗦𝗜𝗡𝗘𝗦𝗦” 𝗚𝗨𝗜𝗗𝗘𝗟𝗜𝗡𝗘𝗦 𝗙𝗢𝗥 𝗧𝗔𝗫 𝗥𝗘𝗚𝗜𝗦𝗧𝗥𝗔𝗧𝗜𝗢𝗡 𝗖𝗔𝗡𝗖𝗘𝗟𝗟𝗔𝗧𝗜𝗢𝗡; 𝗧𝗔𝗫 𝗖𝗟𝗘𝗔𝗥𝗔𝗡𝗖𝗘 𝗥𝗘𝗟𝗘𝗔𝗦𝗘𝗗 𝗔𝗦 𝗙𝗔𝗦𝗧 𝗔𝗦 𝗧𝗛𝗥𝗘𝗘 𝗗𝗔𝗬𝗦

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 47-2026 on May 19, 2026, prescribing new guidelines to simplify the process for closing businesses and cancelling tax registration, as part of the implementation of Republic Act No. 11976, otherwise known as the “Ease of Paying Taxes Act.”

“This is our ‘Ease of Closing Business’ reform,” Commissioner Charlito Martin R. Mendoza said. “In line with President Ferdinand R. Marcos Jr.’s directive to make government services faster, better, and more responsive, and Finance Secretary Frederick D. Go’s push to make tax administration more investor-friendly and business-friendly, the BIR is making it easier for taxpayers who have already ceased operations to properly close their business and cancel their registration.”

“From improving the ease of doing business and the ease of paying taxes, this reform completes the BIR’s support for businesses through every stage of the business life cycle. If we make it easier to start and operate a business, then the government must also make it easier to properly close BIR registration once operations have already ceased,” he added.

Under RMC No. 47-2026, taxpayers who have already ceased operations may now apply for the closure or cancellation of their registration, either manually or electronically, through the Revenue District Office where their head office or branch is registered.

The Circular simplifies and standardizes documentary requirements. Together with the application form and the surrender of original BIR registration documents and permits previously issued to the business, taxpayers will only be required to submit two other document sets for closure: the list of ending inventory of goods and supplies, including capital goods for VAT-registered taxpayers, and the unused invoices, supplementary documents, and other unutilized accounting forms, together with their inventory.

Under the new guidelines, penalties for non-filing of tax returns shall no longer accrue once the taxpayer submits the complete documentary requirements for the closure or cancellation of registration. To prevent the further accumulation of open cases, the taxpayer’s registered form types shall likewise be placed under “deregistered” status upon submission of the complete requirements. Filing an application for the closure or cancellation of registration, however, does not preclude the Bureau from conducting an audit to determine any outstanding tax liabilities.

In addition, micro taxpayers shall not be subject to mandatory audit for closure and/or cancellation of business registration. Hence, tax clearances will be issued within three (3) working days from submission of complete documentary requirements for those with no open cases or outstanding liabilities. For micro taxpayers with open cases, tax clearance will be issued within three (3) working days from the submission of the complete documentary requirements and the payment of outstanding liabilities, including penalties.

Commissioner Mendoza encouraged taxpayers who have already ceased operations to avail themselves of the streamlined process to avoid the continued accumulation of penalties and to properly update their registration records with the Bureau.

Read the full RMC here:https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2047-2026.pdf

28/04/2026

𝗕𝗜𝗥 𝗖𝗟𝗔𝗥𝗜𝗙𝗜𝗘𝗦 𝗥𝗨𝗟𝗘𝗦 𝗢𝗡 𝗣𝗥𝗢𝗢𝗙 𝗢𝗙 𝗦𝗘𝗧𝗧𝗟𝗘𝗠𝗘𝗡𝗧, 𝗜𝗡𝗦𝗧𝗔𝗟𝗟𝗠𝗘𝗡𝗧 𝗣𝗔𝗬𝗠𝗘𝗡𝗧𝗦 𝗙𝗢𝗥 𝗔𝗩𝗔𝗜𝗟𝗠𝗘𝗡𝗧𝗦 𝗢𝗙 𝗘𝗦𝗧𝗔𝗧𝗘 𝗧𝗔𝗫 𝗔𝗠𝗡𝗘𝗦𝗧𝗬

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 33-2026 to clarify specific rules on filing and payment of estate tax under the Estate Tax Amnesty.

The Circular, posted on April 27, 2026, provides guidance on the submission of proof of settlement, treatment of undeclared estate properties, and installment payment arrangements for taxpayers who availed of the Estate Tax Amnesty.

On the submission of proof of estate settlement, the Circular states:

“There is no deadline to submit the proof of settlement of estate. Non-submission of such proof on or before the June 16, 2025 deadline for availing the Estate Tax Amnesty does not invalidate the application. However, it is important to note that the proof of settlement is required for the processing and issuance of the eCAR, which is necessary for the transfer of the estate’s assets.”

The Circular also addresses cases where additional estate properties are discovered after the filing of the Estate Tax Amnesty Return. It clarifies that properties not included in the original return are not covered by the Estate Tax Amnesty and shall be taxed under the applicable estate tax laws in effect at the time of the decedent’s death.

RMC No. 33-2026 further provides that installment payment may be allowed, subject to prior approval of the concerned Revenue District Officer. Payment may be made within two years from the statutory date of payment, without civil penalties and interest, provided that the first installment was paid on or before June 16, 2025.

Failure to pay any installment on time will result in the forfeiture of the amnesty availment. The estate will then be subject to the applicable estate tax laws at the time of the decedent’s death, including corresponding penalties.

“This Circular is meant to remove confusion for taxpayers who already availed of the Estate Tax Amnesty before the deadline and are now completing the settlement and transfer of estate properties,” Commissioner Charlito Martin R. Mendoza said.

28/04/2026

28/04/2026

The (SC) has acquitted a mother of parricide over her daughter’s death, exempting her from criminal liability after finding that she has schizophrenia and her mental state deprived her of the capacity to recognize the wrongfulness of her act.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division granted a mother’s appeal and overturned her parricide conviction on the ground of legal insanity due to schizophrenia, an exempting circumstance under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦.

The mother was charged with parricide for the killing of her five-year old daughter after she was seen embracing the child and simultaneously jumping off a bridge into a river with her, which led to her daughter’s death. While a man aboard a styrofoam banca was able to save the mother, he was unable to locate the child. The daughter’s lifeless body was found in the river the next day.

The mother claimed she was not in her right mind at the time. She could only remember walking with her daughter and had no memory of the incident itself. She said she only regained consciousness while floating in the water.

A licensed physician from the National Center for Mental Health (NCMH) testified that the mother was diagnosed with schizophrenia.

The Regional Trial Court (RTC) brushed aside the claim of insanity as she entered into a plea of “not guilty” and raised insanity as a defense only after the prosecution rested its case. The RTC convicted the mother and sentenced her to reclusion perpetua after finding that she was sane at the time of the incident.

The Court of Appeals affirmed the RTC’s decision.

The SC disagreed. It ruled that the mother was not criminally liable because her mental condition during the incident prevented her from understanding the nature and wrongfulness of her actions.

Insanity is defined as a disease or defect of the brain manifested in language or conduct. Under Article 12 of the Revised Penal Code, it is one of the circumstances that exempts a person from criminal liability.

In 𝙋𝙚𝙤𝙥𝙡𝙚 𝙫. 𝙋𝙖ñ𝙖, the SC laid down a three-way test to establish insanity as an exempting circumstance:

• 𝙛𝙞𝙧𝙨𝙩, the insanity must be present at the time of the commission of the crime;
• 𝙨𝙚𝙘𝙤𝙣𝙙, it must be medically proven; and
• 𝙩𝙝𝙞𝙧𝙙, it must render the accused incapable of appreciating the nature and quality or the wrongfulness of the act.

Insanity must be proven with clear and convincing evidence. Because it involves a person’s state of mind, courts look at overt acts or outward behavior. As a rule, insanity must be supported by medical evidence, unless there are extraordinary circumstances where such evidence is not available. While people who know the accused may testify about their observations, courts give greater weight to the findings and evaluations of qualified medical experts.

In this case, the SC determined that the mother was able to medically prove that she was suffering from schizophrenia at the time of the crime based on the testimony and mental status examination reports from psychiatrists.

The SC further explained that schizophrenia is a chronic mental disorder characterized by the inability to distinguish between fantasy and reality. Often accompanied by hallucinations and delusions, the medical condition deprives a person of discernment, satisfying the third requisite in the 𝘗𝘢ñ𝘢 𝘥𝘰𝘤𝘵𝘳𝘪𝘯𝘦.

Here, the psychiatrist testified that the mother was mentally disturbed at the time of the incident, showing signs of paranoia and perceiving threats, gossip, and envy directed at her.

While the SC exempted the mother from criminal liability, it still held her civilly liable and ordered her to pay the victim’s heirs PHP 75,000 in civil indemnity and PHP 200,000 in moral, exemplary, and temperate damages.

The SC also ordered the mother’s immediate transfer from the Correctional Institution for Women to the NCMH for her treatment. She will be released only upon the order of the RTC based on a recommendation from her attending physician at the hospital.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=164320

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164308

Copying of this content is subject to the SC PIO’s Credit Attribution Policy.

20/04/2026

The (SC) has affirmed its previous ruling that cyber libel prescribes one year from the time it is discovered, holding that “cyber libel” is not a new crime but a form of “libel” under Art. 355 of the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 that is committed through a computer system or other similar means.

In a Resolution written by Associate Justice Henri Jean Paul B. Inting, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 denied the separate motions for reconsideration filed by Berteni Cataluña Causing and the Office of the Solicitor General (OSG).

In December 2020, Cotabato Second District Representative Ferdinand L. Hernandez filed a cyber libel complaint with the prosecutor against Causing related to Facebook posts accusing Hernandez of pocketing over PHP 200 million in relief goods for Marawi victims. Hernandez stated he discovered the posts on February 4 and April 29, 2019.

Informations were filed before the Regional Trial Court (RTC) against Causing in May 2021. He filed a motion to quash the Informations, arguing that they were already time-barred under the RPC because more than one year had passed since the posts were uploaded.

The RTC denied the motion, ruling that cyber libel prescribes in 12 years under 𝘙𝘦𝘱𝘶𝘣𝘭𝘪𝘤 𝘈𝘤𝘵 𝘕𝘰. (𝘙𝘈) 10175 or the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵.

Causing appealed to the SC, which clarified that the prescriptive period for cyber libel is one year from the date of discovery, consistent with traditional libel under the RPC. The Court rejected Causing’s motion to quash the Informations due to insufficient proof that the offense had already prescribed, highlighting that he can present evidence during the trial at the RTC.

Both the OSG and Causing filed separate partial motions for reconsideration.

The OSG argued that the one-year prescriptive period for traditional libel under the RPC should not apply to cyber libel. Instead, it should be 15 years under the Cybercrime Prevention Act, as previously decided by the Supreme Court through an unsigned resolution in Tolentino v. People.

Causing, on the other hand, argued that the prescription for cyber libel should start from the publication date rather than from discovery. He contended that online posts are more widespread than traditional forms of publication. If the discovery rule is applied, cyber libel charges could be filed several years after the post was made, as long as the offended party discovered it later.

The SC rejected both arguments.

Under the RPC, written libel prescribes in one year. There is no law that excludes cyber libel from this one-year period, and Congress has consistently treated libel as having a shorter prescriptive period than other crimes, even when penalties are increased.

The SC reiterated that cyber libel is not a separate crime, but rather libel committed through a computer system. The fact that the Cybercrime Prevention Act imposes a higher penalty for cyber libel does not imply that its prescriptive period should be extended beyond that of traditional libel.

The SC added that when laws on the prescription of crimes are unclear, they must be interpreted in favor of the accused. Since the RPC sets a one-year prescriptive period for cyber libel, it prevails over the 15-year period set in the case of Tolentino v. People, which is an unsigned resolution.

The SC also affirmed that prescription begins upon discovery of the offense, not upon publication. The law clearly states that prescription runs from the time the crime is discovered by the offended party or the authorities.

Seven other Justices joined Justice Inting in the majority. They are:
• Chief Justice Alexander G. Gesmundo
• Senior Associate Justice Marvic M.V.F. Leonen
• Associate Justice Alfredo Benjamin S. Caguioa
• Associate Justice Rodil V. Zalameda
• Associate Justice Samuel H. Gaerlan
• Associate Justice Jose Midas P. Marquez
• Associate Justice Maria Filomena D. Singh

In his Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen argued that the one-year prescription period should apply only to libel cases against private individuals. He added that libel against public figures should be decriminalized, as punishing comments and criticisms directed at public officials discourages free and uninhibited discussion about how those in public office conduct themselves.

In his Concurring Opinion, Associate Justice Alfredo Benjamin S. Caguioa stressed that the prescriptive period for libel has always been fixed at one or two years, never at 10 or more years.

Meanwhile, six other Justices joined Associate Justice Antonio T. Kho, Jr. in his dissent:
• Associate Justice Ramon Paul L. Hernando
• Associate Justice Amy C. Lazaro-Javier
• Associate Justice Ricardo R. Rosario
• Associate Justice Jhosep Y. Lopez
• Associate Justice Japar B. Dimaampao
• Associate Justice Raul B. Villanueva

In his Concurring and Dissenting opinion, Justice Kho, Jr. agreed with the majority that unsigned resolutions do not lay down doctrines of law but disagreed on the prescriptive period for cyber libel. Since cyber libel is committed through computer systems and is punishable under the Cybercrime Prevention Act, it is a separate crime from libel and the one-year prescriptive period for libel does not apply.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=163671

Read the full text of the Resolution at https://sc.judiciary.gov.ph/?p=163636

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=163642

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/wp-admin/post.php?p=163650

Read the Concurring and Dissenting OpinionOpinion of Associate Justice Antonio T. Kho, Jr. at https://sc.judiciary.gov.ph/?p=163661

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution

17/04/2026

"BOTH SEXES ARE CAPABLE OF INFIDELITY"

Senior Associate Justice Marvic Leonen has reminded the public to avoid stereotyping women as automatic victims and labeling all unfaithful men as abusers, stressing that both men and women are equally capable of disloyalty that could result in psychological harm to their partners.

Leonen made these remarks in his dissenting opinion on a recent ruling of the Supreme Court's Second Division, which convicted a man of psychological violence after he abandoned his wife to live with his mistress, with whom he had two children.

He ruled that the prosecution failed to prove beyond reasonable doubt the causal link between the husband's infidelity and the alleged psychological suffering of his wife.

The magistrate underscored that while infidelity is inherently painful, the justice system should not aggravate that pain by pursuing what he described as a misplaced desire for revenge through incarceration and instead suggested that spouses be encouraged to seek fair and balanced resolutions to marital conflicts.

Leonen also emphasized that marital infidelity alone does not automatically constitute psychological violence, the prosecution must be clearly established that the act directly caused mental or emotional suffering to the victim.

"I remain steadfast in my commitment to uphold the protection of women and their children against all forms of violence. The enactment of Republic Act No. 9262 has empowered more and more women to see themselves as equals to men and to recognize that they do not deserve to suffer any form of violence simply because of their s*x." Leonen stressed.

17/04/2026

The (SC) has ruled that sounds incident to the operation of an educational institution, those arising from a school’s regular activities, are not considered a nuisance and cannot make the school liable for damages.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division granted the petition of Couples for Christ School of the Morning Star (School) and reversed the Court of Appeals’ (CA) ruling that awarded damages to residents of Saint Joseph Subdivision in Barangay Villa Kananga, Butuan City, where the school is located.

Wideline I. Malonda and others, who are residents of the Subdivision, claimed they were often exposed to loud noises from the School, such as drums and bugles being played, teachers speaking through microphones and megaphones, and students running, cheering and shouting during games played at the multipurpose center.

The residents claimed that these sounds, heard day and night, disturbed their sleep and peace at home.

In its defense, the School said it has been operating since 2012 with the necessary permits and clearances and that any noise comes only from regular classes. It added that the City Environment and Natural Resources Office conducted a test and found the noise to be within the allowed limits for residential areas. The School also claimed it took steps to reduce noise, such as building higher fences, planting trees, using small speakers, and limiting activities to 7:00 a.m. to 7:00 p.m. on weekdays.

The Regional Trial Court (RTC) dismissed the residents’ complaint, ruling that they failed to prove they were harmed by the noise. The RTC also found that the School did not intend to harm the residents and acted in good faith by taking steps to reduce the noise.

On appeal, the CA ruled in the residents’ favor, holding that the School’s noise, which came not only from classes but also from other social functions in the multi-purpose hall, was a nuisance that caused discomfort and annoyance to the residents.

The SC overturned the CA’s ruling. It held that academic noise, or sounds from legitimate school activities, is not a nuisance.

Nuisance includes any disturbance that interferes with a person, property or comfort and enjoyment of all citizens. The SC ruled that the determination of whether a noise is a nuisance requires more than just considering the location, environment, and its effect on residents.

Thus, for noise to be considered nuisance, the SC considered in the 𝘍𝘳𝘢𝘣𝘦𝘭𝘭𝘦 𝘗𝘳𝘰𝘱𝘦𝘳𝘵𝘪𝘦𝘴 𝘊𝘰𝘳𝘱. 𝘷. 𝘈𝘊 𝘌𝘯𝘵𝘦𝘳𝘱𝘳𝘪𝘴𝘦𝘴 𝘐𝘯𝘤. the:

1. reliability of the noise pollution tests conducted,
2. introduction by the defendant of measures or improvements to mitigate the noise,
3. allowable noise levels,
4. defendant’s intention (or lack thereof) to cause harm to the plaintiff,
5. number of complaining witnesses,
6. representativeness of the plaintiff, and
7. actions of the plaintiff to alleviate his or her plight.

Adopting the framework, the SC finds that the sounds emanating from the School arose from its ordinary operations as an educational institution, and that the respondents are hardly representative of the community.

The SC also ruled that the residents failed to prove that the noise was unreasonably disturbing and that it worsened their health conditions. The residents’ statements showed only minor discomforts, not serious harm.

The SC added that while location and environment are important in determining a nuisance, they must be weighed against whether the noise is normally expected from the activity involved. Here, the sounds complained of did not go beyond what could be reasonably expected from a school.

The SC emphasized that there is no nuisance if an ordinary person would not find the sound disturbing, even if someone else is unusually sensitive to it.

The SC explained:

“𝘓𝘪𝘷𝘪𝘯𝘨 𝘪𝘯 𝘢 𝘥𝘦𝘯𝘴𝘦𝘭𝘺 𝘱𝘰𝘱𝘶𝘭𝘢𝘵𝘦𝘥 𝘤𝘰𝘶𝘯𝘵𝘳𝘺 𝘴𝘶𝘤𝘩 𝘢𝘴 𝘵𝘩𝘦 𝘗𝘩𝘪𝘭𝘪𝘱𝘱𝘪𝘯𝘦𝘴, 𝘸𝘩𝘦𝘳𝘦 𝘩𝘰𝘶𝘴𝘦𝘴 𝘢𝘯𝘥 𝘣𝘶𝘴𝘪𝘯𝘦𝘴𝘴𝘦𝘴 𝘢𝘳𝘦 𝘴𝘪𝘵𝘶𝘢𝘵𝘦𝘥 𝘪𝘯 𝘤𝘭𝘰𝘴𝘦 𝘱𝘳𝘰𝘹𝘪𝘮𝘪𝘵𝘺, 𝘢𝘮𝘱𝘭𝘪𝘧𝘪𝘦𝘴 𝘱𝘦𝘰𝘱𝘭𝘦’𝘴 𝘴𝘦𝘯𝘴𝘪𝘵𝘪𝘷𝘪𝘵𝘺 𝘵𝘰 𝘯𝘰𝘪𝘴𝘦. 𝘏𝘰𝘸𝘦𝘷𝘦𝘳, 𝘯𝘰𝘵 𝘢𝘭𝘭 𝘬𝘪𝘯𝘥𝘴 𝘰𝘳 𝘭𝘦𝘷𝘦𝘭𝘴 𝘰𝘧 𝘯𝘰𝘪𝘴𝘦 𝘢𝘳𝘦 𝘢𝘤𝘵𝘪𝘰𝘯𝘢𝘣𝘭𝘦. 𝘗𝘢𝘳𝘵𝘪𝘤𝘶𝘭𝘢𝘳𝘭𝘺, 𝘵𝘩𝘦 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦 𝘳𝘦𝘨𝘢𝘳𝘥𝘴 𝘯𝘰𝘪𝘴𝘦 𝘢𝘴 𝘢 𝘯𝘶𝘪𝘴𝘢𝘯𝘤𝘦 𝘰𝘯𝘭𝘺 𝘸𝘩𝘦𝘯 𝘪𝘵 𝘳𝘦𝘢𝘤𝘩𝘦𝘴 𝘢𝘯 𝘪𝘯𝘵𝘦𝘯𝘴𝘪𝘵𝘺 𝘵𝘩𝘢𝘵 𝘪𝘯𝘫𝘶𝘳𝘦𝘴 𝘰𝘳 𝘦𝘯𝘥𝘢𝘯𝘨𝘦𝘳𝘴 𝘵𝘩𝘦 𝘩𝘦𝘢𝘭𝘵𝘩 𝘰𝘳 𝘴𝘢𝘧𝘦𝘵𝘺 𝘰𝘧 𝘰𝘵𝘩𝘦𝘳𝘴, 𝘰𝘳 𝘢𝘯𝘯𝘰𝘺𝘴 𝘰𝘳 𝘰𝘧𝘧𝘦𝘯𝘥𝘴 𝘵𝘩𝘦 𝘴𝘦𝘯𝘴𝘦𝘴.”

The SC also denied the claim for damages since the School did not intend to harm or annoy the residents and had taken steps to reduce the noise. There was no evidence that the school caused the noise willfully, with malice or bad faith.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=163502

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=163486

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/278875-formerly-udk-no-18061-concurring-opinion-justice-alfredo-benjamin-s-caguioa/

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution

14/04/2026

14/04/2026

𝗕𝗜𝗥 𝗣𝗨𝗕𝗟𝗜𝗦𝗛𝗘𝗦 𝗨𝗣𝗗𝗔𝗧𝗘𝗗 𝗟𝗜𝗦𝗧 𝗢𝗙 𝟮,𝟮𝟲𝟯 𝗩𝗔𝗧-𝗘𝗫𝗘𝗠𝗣𝗧 𝗠𝗘𝗗𝗜𝗖𝗜𝗡𝗘𝗦

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 27-2026 on April 8, 2026, publishing the FDA-endorsed full list of VAT-exempt drugs under Republic Act No. 10963, or the TRAIN Law, and Republic Act No. 11534, or the CREATE Act.

The Food and Drug Administration Philippines (FDA) of the Department of Health (Philippines) endorsed the updated list of 2,263 VAT-exempt drugs for the treatment of the following illnesses: 702 for cancer, 535 for hypertension, 327 for diabetes, 300 for mental illness, 171 for high cholesterol, 152 for kidney disease, and 76 for tuberculosis.

In line with President Ferdinand R. Marcos Jr.’s directive to make healthcare more accessible and affordable for Filipinos, the Department of Finance, under Finance Secretary Frederick D. Go, supports the timely implementation of measures that help reduce the cost of essential medicines.

BIR Commissioner Charlito Martin R. Mendoza said, “This issuance forms part of the government’s continuing efforts to help ease the cost of essential medicines, especially for Filipinos managing chronic and critical illnesses.”

RMC No. 27-2026 further provides that the updated list supersedes previous revenue memorandum circulars issued on the matter and shall remain in effect until new updates are endorsed by the FDA.

You may access the full text of RMC No. 27-2026 here(https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2027-2026.pdf), while the complete list of VAT-exempt medicines is available through Annex A of the circular (https://bir-cdn.bir.gov.ph/BIR/pdf/Annex%20A%20of%20RMC%20No.%2027-2206%20(1).pdf).