MANILA INTERNATIONAL AIRPORT AUTHORITY (MIAA) vs. CA

"Ey where's Dory??!!" Woops! somebody's excited to see 'Finding Dory' in the cinemas.  After 13 years my goodness!! Finally!! We found Dory.

Try to check this out this is original. Manila International Airport Authority (MIAA) is the operator of the Ninoy International Airport (NAIA) formerly known as MIA (Manila International Airport) located at Paranaque City of course. 

I wonder why its name was changed in the first place when MIA has more of a universal touch  to it.  Well now that President Duterte is taking over, and obviously we can sense that he is allergic to anything Liberal Party, I wonder if he would revert back NAIA's name to MIA. Well I hope he does. NAIA sounds like something that is wanting to be inclusive but by it sound still is exclusive.

Thing is.. I wonder how would we refer to it.  "Ah.. lets meet at the MIA formerly know as NAIA which was formerly know as MIA".  Geez  funny I remember this upperclassman friend of mine when I was still new in my previous law school.   His name's Prince. So whenever I see him at the corridor or maybe introduce him to lady batchmates I always refer to him (in a kidding mode)  as "Prince!!.. formerly known as The Artist.. which was formerly known as Prince" LOL. (I'm reminded of Prince.. God bless his soul) "Chip you suck!"  The guy just laughs reaches out and tickles my tummy. Ah he's such a nice friend. Works at a big bank in Makati. The guy's a prince really. His car's really nice. And such a nice guy too. I always saw him as an upperclassman whose not puffed-up.  Well anyway.  

So what happened here was.. the Officers of Paranaque City sent notices to MIAA due to real estate tax delinquency. MIAA then settled some of the amount. 

Now when MIAA failed to settle the entire amount, the officers of Paranaque city threatened to levy and subject to auction the land and buildings of MIAA, which they did. 

MIAA then sought for a Temporary Restraining Order (TRO) from the CA but failed to do so within the 60 days reglementary period, so the petition was dismissed. 

MIAA then sought for the TRO with the Supreme Court a day before the public auction, MIAA was granted with the TRO but unfortunately the TRO was received by the Paranaque City officers 3 hours after the public auction.  See what I told you?  See how original this case was?  I mean what on earth was MIAA doing??  Talk about all the right moves.

MIAA claims that although the charter provides that the title of the land and building are with MIAA still the ownership is with the Republic of the Philippines. MIAA also contends that it is an instrumentality of the government and as such exempted from real estate tax.  So in other words, MIAA's bone of contention and defense lie solely on the principle that the land and buildings of MIAA are of public dominion and therefore cannot be subjected to levy and auction sale. 

Let's see if it will hold. 

On the other hand, the officers of Paranaque City claim that MIAA is a GOCC (government owned and controlled corporation) therefore not exempted to real estate tax. 

ISSUE:

Whether or not:

1. MIAA is an instrumentality of the government and not a government owned and controlled corporation and as such exempted from tax.

2. The land and buildings of MIAA are part of the public dominion and thus cannot be the subject of levy and auction sale.

RULING:

1. Under the Local government code, (GOCCs) government owned and controlled corporation are NOT exempted from real estate tax.

MIAA is not a government owned and controlled corporation, for to become one MIAA should either be a stock or non stock corporation. MIAA is not a stock corporation for its capital is not divided into shares. It is not a non stock corporation since it has no members.

MIAA is an instrumentality of the government vested with corporate powers and government functions. Under the civil code, property may either be under public dominion or private ownership. Those under public dominion are owned by the State and are utilized for public use, public service and for the development of national wealth. When properties under public dominion cease to be for public use and service, they form part of the patrimonial property of the State.

2. The court held that the land and buildings of MIAA are part of the public dominion. Since the airport is devoted for public use, for the domestic and international travel and transportation. Even if MIAA charge fees, this is for support of its operation and for regulation and does not change the character of the land and buildings of MIAA as part of the public dominion.

As part of the public dominion the land and buildings of MIAA are outside the commerce of man. To subject them to levy and public auction is contrary to public policy. Unless the President issues a proclamation withdrawing the airport land and buildings from public use, these properties remain to be of public dominion and are inalienable. As long as the land and buildings are for public use the ownership is with the Republic of the Philippines

MIAA wins this case.  Well I guess it has after all the luxury to take lightly such period prescriptions in this case.  It knew very well from the start its contentions will be very strong.

SOUTH AFRICAN AIRWAYS vs. CIR

Now lets go to another airline. South African Airways. Tell me the truth, you didn't think there was such did you? I don't blame you. First time I heard it too.

The difference of this case from the last two previous case is that the BIR was the petitioner in the last two cases. Here the petitioner was the airline itself. 

So petitioner South African Airways (SAA) is a foreign corporation organized and existing under and by virtue of the laws of the Republic of South Africa. Its principal office is located at Airways Park, Jones Road, Johannesburg International Airport, South Africa. 

In the Philippines, it is an internal air carrier also having NO LANDING RIGHTS in the country.  And like both previous airlines Petitioner herein has a general sales agent in the Philippines in the person of Aerotel Limited Corporation (Aerotel).  No they weren't selling tickets.  Aerotel sells passage documents for compensation or commission for petitioner’s off-line flights for the carriage of passengers and cargo between ports or points outside the territorial jurisdiction of the Philippines.   

The thing was, petitioner is not registered with the SEC as a corporation, branch office, or partnership. It is not licensed to do business in the Philippines. It paid a corporate tax in the rate of 32% of its gross billings. 

However, it subsequently claim for refund contending that its income should be taxed at the rate of 2 1/2% of its gross billings.

ISSUE:

Is petitioner’s income sourced within the Philippines and is to be taxed at 32% of the gross billings?

HELD:

The answer was YES! 

Court said in the instant case, the General Rule is that resident foreign corporations shall be liable for a 32% income tax on their income from within the Philippines, Except for resident foreign corporations that are international carriers that derive income “from carriage of persons, excess baggage, cargo and mail originating from the Philippines” which shall be taxed at 2 1/2% of their Gross Philippine Billings. 

Petitioner, being an international carrier with no flights originating from the Philippines, does not fall under the exception. As such, petitioner must fall under the general rule. 

(This principle is embodied in the Latin maxim, exception firmat regulam in casibus non exceptis, which means, a thing not being excepted must be regarded as coming within the purview of the general rule.)

To reiterate, the correct interpretation of the above provisions is that, if an international air carrier maintains flights to and from the Philippines, it shall be taxed at the rate of 2 1/2% of its Gross Philippine Billings, while international air carriers that do not have flights to and from the Philippines but nonetheless earn income from other activities in the country will be taxed at the rate of 32% of such income.

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So I believe JAL  though being a non-resident foreign corporation (contrary to the first requisite in the general rule)  was taxed at 32% gross on billings, having absence of flight operations to and from Philippines.  

Question:  There being absence of flight operations to and from Philippines in the JAL case and there having no landing rights and thus did not carry passengers and/or cargo to or from the Philippines in the BOAC case, then why is BOAC taxed at the rate of 2 1/2% gross on billings. 

Here in this case SAA was selling off-line flights outside Philippine territorial jurisdiction and not licensed to do business in the Philippines. So it was taxed at 32% since it falls under the exception. 

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THOUGHTS ON LANDING RIGHTS

You might question the strictness of Philippine government over the question of giving landing rights. You see we cannot just extend our facilities on a reciprocal basis to other countries when we do not have the capacity to fully benefit from the arrangement.  You see our national flag carrier is Philippine Airlines, and so a question will therefore be expected to be thrown at us on how profitable PAL will be (even though now that it's privatized) if the government gives away landing rights that easily to numerous foreign airlines. Well the least that its doing is collecting taxes from revenues from other airlines derived within our territory. 

However, it would be unfair to passengers foreign and domestic alike to deprive them of the facility of other airlines. Right? tsk tsk tsk.  

I think we need efficient management when it comes to this.  

So SAA of course lost this case.

CIR vs. JAPAN AIRLINES (JAL)

Let's go to another airline. Still on the issue of SITUS in taxation. This is actually a reiteration of the decision promulgated in CIR vs. BOAC. The case previously posted.

I'm sure you know Japan Airlines right? Don't you turn Japanese on me... "I think I'm turning Japanesa think am turnin Japanesa.. tarararattattarat..."   Sorry, got carried way.

Well JAL is also a foreign corporation likewise engaged in the business of International air carriage. 

Now if British Overseas Airways Corp. (BOAC) merely used ticket sales agent and stayed at bay. The Japs did it differently JAL maintained an office at the Filipinas Hotel, Roxas Boulevard Manila since mid-July of 1957.  

The said office did not sell tickets but was merely for the promotion of the company.  

But that's what they think.  On July 17 1957, JAL constituted Philippine Airlines (PAL) as its ticket agent in the Philippines. PAL therefore sold tickets for and in behalf of JAL. Same as BOAC there was absence of flight operations to and from the Philippines in this case. Meaning JAL likewise had no landing rights. And so like BOAC what were talking about here are connecting flights.

So obviously this didn't escape the long 'nose'.. I mean claws of the BIR. On June 1972, JAL received deficiency income tax assessments notices and a demand letter from petitioner CIR for years 1959 through 1963. 

Of course JAL protested as BOAC did, against said assessments alleging that as a non-resident foreign corporation, it is taxable only on income from Philippines sources as determined by section 37 of the Tax Code, there being no income on said years, JAL is not liable for taxes.

ISSUE:

Whether or not the proceeds from sales of JAL tickets sold in the Philippines by Philippine Airlines (PAL) are taxable as income from sources within the Philippines.

HELD:

YES.  Court said the ticket sales are taxable.

Citing the case of CIR v BOAC, the court reiterated that the source of an income is the property, activity or service that produced the income. For the source of income to be considered as coming from the Philippines, it is sufficient that the income is derived from activity within the Philippines. 

The absence of flight operations to and from the Philippines is not determinative of the source of income or the situs of income taxation. 

The test of taxability is the source, and the source of the income is that activity which produced the income. In this case, as JAL constituted PAL as its agent, the sales of JAL tickets made by PAL is taxable

JAL likewise lost this case.

A Watchful Guardian

"He's a silent guardian, a watchful protector. A dark knight"  

I'm looking for a particular Batman DC Comics. Not the one with cartoon figures drawn on it but the one with CGI pictures. Like the Batman Arkham Origins. The one when you're reading it's like you're playing a video game and not reading an ordinary 2 dimensional comic book.  It's actually a present, a birthday gift for a little boy of about 9 years old in this neighborhood. His name is Patrick. I call him Patrick Star. You see last week I got invited to a kiddie party. So Saturday the kids were here but I wasn't around, I got summer class.  Kiddie party would you believe?  Actually the kids are friends. And the one whose very close to me celebrated his birthday just this Saturday.  He came Sunday co'z were suppose to paint his bike black and put a bat emblem on it so I asked him how the party was. He said he got lots of guests and the food was great, and I wasn't around. So.. of course he understands. I said I'll make it up to him.  That's why I'm looking for a Batman Arkham Comic Book for his present.      

   

PEPSI COLA BOTTLING COMPANY PHILIPPINES vs. TANAUAN

                                                                                    

Question:  Can power to tax which is a purely legislative act be delegated?

Answer: YES.  Not to the Executive nor to the Judicial department (which violates the doctrine of Separation of Powers) but to Local Government. 

Further Question:  Can Double Taxation be allowed?

Further Answer: It's NOT forbidden by law, unless the taxpayer is taxed twice for the same benefit of the same governmental entity or by the same jurisdiction for the same purpose,

FACTS:

Pepsi, appellant in this case commenced a complaint with preliminary injunction assailing  Sec.2 of R.A. 2264 otherwise known as the LOCAL AUTONOMY ACT stating the following:

1. That there is UNDUE DELEGATION OF THE TAXING AUTHORITY 

2. To declare ORDINANCES Nos. 23 and 27 was unconstitutional which allows DOUBLE TAXATION

3. Subject ordinances are void for they impose PERCENTAGE TAX or SPECIFIC TAX

Ordinance No. 23 – Levies and collects from soft drink producers and manufacturers a tax of 1/16th of a centavo for every bottle of soft drink corked.

Ordinance No. 27 – Levies and collects on soft drinks produced or manufactured within the territorial jurisdiction of the Municipality of Tanauan a tax of 1 Centavo (P0.01) on each gallon of volume capacity.  

ISSUE:

Are the contentions of the appellant tenable?   

RULING:

1.   On the issue of UNDUE DELEGATION of Taxing Power - It is settled that the power of taxation is an essential and inherent attribute of sovereignty, belonging as a matter of right to every independent government, without being expressly conferred by the people. 

It is a power that is purely Legislative and which the central legislative body cannot delegate either to the Executive or Judicial department of the government without infringing upon the theory of separation of powers. 

However there is an exception to this. In cases OF MUNICIPAL CORPORATIONS to which said theory does not apply. Legislative powers MAY BE DELEGATED TO LOCAL GOVERNMENTS in respect of matters of local concern.  By necessary implication, the legislative power to create political corporations for purposes of local self-government carries with it the power to confer on such local governmental agencies the power to tax. 

2.  On the issue on DOUBLE TAXATION -  There is no validity to the assertion that the delegated authority can be declared unconstitutional on the theory of double taxation.   It must be observed that the delegating authority specifies the limitations and enumerates the taxes over which local taxation may not be exercised. The reason is that the state has exclusively reserved the same for its own prerogative.  

Double Taxation in general is NOT FORBIDDEN BY OUR FUNDAMENTAL LAW.  Double Taxation becomes obnoxious only when the taxpayer is taxed twice for the same benefit of the same governmental entity or by the same jurisdiction for the same purpose, but not in a case where one tax is imposed by the state and the other by the city or municipality. 

3. Last issue raised regarding the PERCENTAGE TAX issue -  The ordinances do not partake of the nature of percentage tax . The tax is levied on the PRODUCE  (whether sold or not)  and not on the sales. 

ABRA VALLEY COLLEGE INC. vs. AQUINO

This is an old taxation case which had been covered by the 1935 Constitution. 

Question:  Is tax exemption which is embraced in the words "Exclusively Used for Educational Purposes"  liberally construed?  

Answer:  YES.

Therefore: A reasonable emphasis can be made that the tax exemption may extend to facilities which are INCIDENTAL TO and REASONABLY NECESSARY for the accomplishment of the main purpose (which is to educate). 

Further Question: Can a ground floor of an educational institution (which is tax exempted), being used for commercial purpose and its second floor being used for residential purpose fall under said extension? 

Further Answer:  The residential issue may be qualified depending on who is residing. The commercial issue? NO.

FACTS:

Abra Valley College (a private school), located at Benguet, Abra, an educational corporation and institution of higher learning incorporated with the SEC filed a complaint with the Benguet provincial fiscal to annul and declare void the NOTICE OF SEIZURE and a NOTICE OF SALE of its lot and building by the municipal and provincial treasurers for non-payment of real estate taxes and its penalties. 

So a certain Paterno Mellare who probably was with Public Respondent AQUINO (sorry I didn’t read any further) who most probably (patay to, I’m inferring once again) are the municipal and provincial treasurers filed through counsel a motion to dismiss the complaint.

So what the Provincial Fiscal did was they filed a memorandum for the government where they opined that based on the evidence, the laws applicable, and previous court decisions and jurisprudence, the school building and the school lot used for educational purpose of Abra Valley College are exempted from payment of taxes. 

The trial court disagreed.  Lets try to look at the evidence and what they found out. 

You see what actually happened here was that Abra Valley College (AVC) was renting out the ground floor of its college building to Northern Marketing Corporation (NMC)  while the second floor thereof is used by the Director of the College for residential purposes.  So this is precisely the reason why the municipal and provincial treasurers served upon the College a “notice of seizure” and later a “notice of sale” due to the alleged failure of the College to pay real estate taxes and penalties thereon. 

So this falls under a case of a claim for tax exemption.  

ISSUE: 

Was the tax imposition on the College is violative of the Constitutional prohibition against taxation of religious, charitable, and educational entities?

Maybe we should rephrase the question. The question is, whether or not the lot and building in question are used exclusively for educational purpose?  E pinaparenta yung ground floor eh, ginawa namang residential yung second floor. Kaya siguro sinabe ng municipal and provincial treasurers “Pinaglololoko nyo kame, ok tataxan namen kayo, and pag di na kayo makabayad, we will seize that property, then we will sell it”  (again don’t quote me on that, para may istorya lang). 

RULING:

While the Court allows a more liberal and non-restrictive interpretation of the phrase “exclusively used for educational purposes,” reasonable emphasis has always been made that exemption extends to facilities which are incidental to and reasonably necessary for the accomplishment of the main purposes. 

While the second floor’s use, as residence of the director, is incidental to education; the lease of the first floor cannot by any stretch of imagination be considered incidental to the purposes of education. 

The test of exemption from taxation is the use of the property for purposes mentioned in the Constitution. 

So there we go. Let's reiterate:  While the use of the second floor of the main building in the case at bar for residential purposes of the Director of the school and his family may find justification under the concept of INCIDENTAL USE, which is complimentary to the main or primary purpose which is educational, the lease of the first floor thereof to the Northern Marketing Corporation cannot by any stretch of imagination be considered incidental to the purpose of education.

So the Supreme Court affirmed the lower court ruling stating it correctly arrived at the conclusion that the school building as well as the lot where it is built, should be taxed. Not because of the second floor issue but of the first floor. 

However since it is only a portion of its premises is used for purpose of commerce, the high court directed that it is only fair that half of the assessed tax be returned to the school. 

CALTEX vs. CIR

Question:  Let’s say you have valid claims of tax refunds. Can you offset your tax due from the refund claims you have? 

1989, COA sent CALTEX a letter directing it to remit its collection to OPSF (Oil Price Stabilization Fund) excluding the unremitted (ad valorem tax) for 1986 and 1988 of the additional tax on petroleum products authorized under Section 8 of PD 1956 (which is the law imposing Ad Valorem tax on certain manufactured oils and other fuels).   

You must understand that CALTEX previously had reimbursement certificates released by OPSF., meaning they have existing tax refund claims. 

And what COA was stating to Caltex in a way was: "E since we excluded your unremitted ad valorem tax for 1986 & 1988 and we've put it on pending, eh di we will hold your reimbursement certificates from the OPSF in abeyance muna.. para patas lang  and laban di ba?"  (O don't quote me on that..LOL). 

And what Caltex seemed to say was: "Eh actually eh... hihingi nga kami ng offset eh". Ofcourse COA denied this request.  

So Caltex submitted to COA a proposal for the payment and together with it the recovery of their claims. What COA did was they approved the proposal but prohibited Caltex from further offsetting remittances and reimbursement for the current and  ensuing years. Caltex therefore moved for reconsideration.

So.. pwede pala i-offset.. 

So in short what's happening here is that Caltex have overpaid OPSF and it wants its refund to pay for its taxes.

ISSUE:

Whether the amounts due from Caltex to the OPSF may be OFFSETTED against Caltex' outsanding claims from said funds. 

HELD:

Court said, Taxation is not only envisioned as a measure merely to raise revenue to support the existence of government. Taxes may be levied with a regulatory purpose such as to provide means for rehabilitation and stabilization of a threatened industry which is affected with public interest as to be within the police power of the state.

Ah OK. So the principle that operates is still the LIFE BLOOD Doctrine. It's just that it is not coming from the state's inherent power of taxation but from it's police power, where the principle is to regulate. 

P.D. 1956 as amended by E.O. 137 explicitly provides that the source of OPSF is taxation. A taxpayer MAY NOT OFFSET taxes due from the claims  that he may have against the government.

Taxes cannot be the subject of compensation because the government and the taxpayer are NOT MUTUAL CREDITORS AND DEBTORS OF EACH OTHER

And furthermore, a CLAIM FOR TAXES IS NOT SUCH A DEBT, DEMAND, CONTRACT or JUDGMENT  AS IS ALLOWED TO BE SET-OFF.

So it's clear, walang offset offset. Bayaran mo muna yung tax due mo bago mo kunin yung claims for refund mo. And you pay only cash.

Well truth is, BIR does not appropriate for tax refunds. Actually what it gives are Tax Credits. Kaya hindi liquidated. 

Caltex lost this case.

Buti na lang.  E di nga sila nagiissue ng recibo eh pag nagpapagas ka and below 300 gas mo. Hihintayin pa nila humingi ka. (sayang daw kasi paper trail).   "Pssst hoy! Recibo ko?"  "Ay sorry sir!"  "Sorry sorry taena!"  LOL.

CITY ASSESSOR OF CEBU vs. BENEVOLA DE CEBU

BENEVOLA DE CEBU is a non-stock non-profit organization and hospital. In 1990 It constructed a Medical Arts building right beside it. In 1998 the CITY ASSESSOR OF CEBU issued a certification classifying the new building as commercial and assessed the building with a market value of roughly P28M, coming up with an assessed value at around close to P10M  at the assessment level of 35% and not 10% which was then currently imposed on private respondent (Benevola de Cebu).  

The City Assessor of Cebu, petitioner in this case claimed that the building is used as commercial clinic/spaces for renting out physicians and thus classified as commercial.

Benevola de Cebu contended that the building is used ACTUALLY, DIRECTLY AND EXCLUSIVELY part of the hospital and should have an assessment level of 10% as it was currently imposed. 

ISSUE:   Whether or not the new building is liable to pay at the 35% assessment level?

RULING:    NO.  It is not commercial. 

We hold that the new building is an integral part of the hospital and should not be assessed as commercial. 

Being a TERTIARY HOSPITAL, it is mandated to be fully departmentalized and be equipped with the service capabilities needed to support certified medical specialists and other licensed physicians.

The fact that they are holding office in a separate building does not take away the essence and nature of their services vis-à-vis the overall operation of the hospital and to patients.

     

Under the Local Government Code, Sec. 26:  “ALL BUILDINGS AND OTHER IMPROVEMENTS THEREON actually, directly, and exclusively used for hospitals, cultural or scientific purposes and those owned and used by local water districts.. shall be classified as SPECIAL  (NOT COMMERCIAL). “

Benevola wins this case.

CIR vs. YMCA

Rule:  Tax Exemption if claimed must be expressly granted in a statute stated in a language TOO CLEAR TO BE MISTAKEN. 

Private respondent YMCA, a  non-stock, non-profit institution which conducts various programs beneficial to the public pursuant to its religious, educational, and charitable objectives LEASES OUT a portion of its premises to small shop owners, like restaurants and canteen operators deriving substantial income from such. 

So seeing this, the Commissioner of Internal Revenue (CIR) issued an assessment to private respondent (YMCA) for  Deficiencies on the following: 1. Income tax, 2. Expanded withholding taxes on rentals and professional fees and 3. Withholding tax on wages.   

YMCA opposed arguing that its rental income is not subject to tax mainly because of the provisions of Section 27 of the NIRC (National Internal Revenue Code) which provides that “civic leagues or organizations not organized for profit but operate exclusively for promotion of social welfare and those organized exclusively for pleasure, recreation and other non-profitable businesses SHALL NOT BE TAXED.” 

ISSUE:   Is the contention of YMCA tenable?

HELD:   NO.   Tax Exemptions are:

1. STRICTLY CONSTRUED:

Because taxes are the LIFEBLOOD of the nation. The court has always applied the Doctrine of Strict Interpretation in construing tax exemptions stated in the language of the law.

2. MANIFEST & UNMISTAKABLE: 

Furthermore, a claim of statutory exemption from taxation should be Manifest and Unmistakable from the language of the law on which it is based.

3. BASED ON LANGUAGE TOO CLEAR TO BE MISTAKEN: 

Thus the claimed exemption “must expressly be granted in a statute stated in a language TOO CLEAR TO BE MISTAKEN.”

YMCA loses this case.

(boy, that's as quickest as we can get)

ABAYA vs. EBDANE, JR.

QUESTION:  Must a Taxpayer be a party to a contract in order to challenge it's validity?

ANSWER:  NO. Ratio: TAXPAYER SUIT  

Petitioners Plaridel M. Abaya who claims that he filed the instant petition as a taxpayer, former lawmaker, and a Filipino citizen, and Plaridel C. Garcia (birds of the same feather ;p) likewise claiming that he filed the suit as a taxpayer, former military officer, and a Filipino citizen, mainly seeking to nullify a DPWH resolution which recommended the award to private respondent China Road & Bridge Corporation of the contract for the implementation of the civil works known as Contract Package No. 1. They also seek to annul the contract of agreement subsequently entered into by and between the DPWH and China Road & Bridge Corporation pursuant to said resolution. 

Respondent defends Petitioners don’t have Locus Standi since they are not party to the contract.

ISSUE:

Do petitioners have the LOCUS STANDI (Legal Standing) to file the instant case against the government notwithstanding  that they are not a party to the contract to challenge its validity?

RULING:

YES. As TAXPAYERS  they have Locus Standi to file the present suit. 

Briefly stated, locus standi is a right of appearance in a court of justice on a given question. More particularly, it is a party’s personal and substantial interest in a case such that he has sustained or will sustain direct injury as a result of the governmental act being challenged. 

Locus standi however is merely a matter of procedure and it has been recognized that in some cases, suits are not brought by parties who have been personally injured by operation of law or any other government act but by concerned citizens, taxpayers or voters who actually sue in the public interest.  Consequently , the court in a catena of cases, has invariably adopted a liberal stance on locus standi, including those cases involving taxpayers. 

Ito yung kaya minsan maynaririnig kang nagfafile ng kaso pero wala naman silang kinalaman sa kontrata or agreement or deal and sinasabi lang nila "at baket taxpayer ako ah? baket ba?".  It is what you call a TAXPAYER’S SUIT. The prevailing doctrine in Taxpayer's Suit is to allow taxpayers to question government contracts especially pag merong

1. illegal disbursement of public funds
2. the public money is being deflected to some other purpose or to someone's private bank account, or they see
3. wastage of public funds through the enforcement of an invalid or unconstitutional law entered into by the national government or GOCCs  allegedly in contravention of the law. 

Significantly, a taxpayer need not be a party to the contract to challenge its validity.  

So if you see the same or have personal knowledge of the same, do remember that as taxpayer, you have the legal standing (locus standi) to file a case in court against the irregularity you see in the government. So di mo na kailangan magsumbong pa kay President Digong, and di mo na din kailangan pang magcreate ng sangkatutak na memes sa social media.  You yourself as taxpayer have the right to question those irregularities in court, kaya sige dong, day, ate, koya ifile mo na yung case, sige te ihugot mo te  :)