Practice question
A taxpayer asks an ordinary RTC to stop BIR collection solely by changing its pleading caption to declaratory relief. Explain why the substantive remedy matters.
Legal references
- NIRC: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section218.
- RA9282 amending RA1125: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html amended Section11.
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