Francis Churchill vs James Rafferty

FACTS: The judgment appealed from in this case perpetually restrains and prohibits the defendant and his deputies from collecting and enforcing against the plaintiffs and their property the annual tax mentioned and described in subsection (b) of section 100 of Act No. 2339, effective July 1, 1914, and from destroying or removing any sign, signboard, or billboard, the property of the plaintiffs, for the sole reason that such sign, signboard, or billboard is, or may be, offensive to the sight; and decrees the cancellation of the bond given by the plaintiffs to secure the issuance of the preliminary injunction granted soon after the commencement of this action.

ISSUE: Whether or not a provision in the internal revenue law prohibiting the courts from enjoining the collection of an internal revenue tax is invalid

RULING: NO. A provision in an internal revenue law prohibiting the courts from enjoining the collection for an internal revenue tax is not invalid as opposed to the due process and equal protection of the law clauses of the bill of rights of the Organic Act. Such legislation has been upheld by the United States Supreme Court

Nor is such a provision of law invalid as curtailing the jurisdiction of the courts of the Philippine Islands as fixed by section 9 of the Organic Act; a) because jurisdiction was never conferred upon Philippine courts to enjoin the collection of taxes imposed by the Philippine Commission; and b) because, in the present case, another adequate remedy has been provided by payment and protest