FIFTEENTH CONGRESS OF HIE 
REPUBLIC OF THE PHILIPPINES 
Firs I Regular Session 
) 
) 
) 
SENATE 
S. RNo .. ~O.87 
Introduced by Senator FRANCIS G. ESCUDERO 
EXPLANATORY NOTE 
This bill mandates the Bureau of Internal Revenue (BIR) to acquire and have 
exclusive jurisdiction over all tax-related cases, thereby doing away with the 
participation of the Department of Justice (DOJ) in the prosecution of said cases. 
This proposed measure is but apt considering the allegations of fraud in the 
National Prosecution Service of the DOJ. Moreover, it hastens delineation of 
responsibilities in the 
tax collections efforts of the governmerlf, maKing 
accountability solely in the hands of the BIR. 
Lastly, it complements Republic Act No. 9282 which expands the jurisdiction 
of the Court of Tax Appeals, by mandating all civil and criminal actions in tax related 
cases cognizable by said court. 
In view of the foregoing, passage of this bill with dispatch is sought. 
FRANCIS G. ESCUDERO 


FIFTEENTH CONGRESS OF TJiE 
REPUBLIC OF THE PHILIPPINES 
first Regular Session 
) 
) 
) 
S"f'",i r~ 
QIHIa or "l ;i';~~CRET""fiV 
J' 
SENATE 
S. B. No. 2087 
Introduced by Senator FRANCIS G. ESCUDERO 
AN ACT 
AMENDING SECTION 220, CHAPTER II, TITLE VIII 
OF REPUBLIC ACT NO. 8424, OTHERWISE KNOWN AS AN ACT 
AMENDING THE NATIONAL INTERNAL REVENUE CODE, AS 
AMENDED, AND FOR OTHER PURPOSES 
Be it enacted by the Serlllte and the House of Representatives of the Philippines in 
Congress assembled: 
<, ... 
SECTION 1. Section 220, Chapter 11, Title VI11 of Hepublic Act No. 8424 
2 
is hereby amended to read as follows: 
3 
"SEC. 220. [Form and Mode of] Proceedings in Actions 
4 
Arising under this Code. - Civil and criminal actions and 
5 
proceedings instituted in behalf of the Government under the 
6 
authority of this Code or other law enforced by the Bureau of 
7 
Internal Revenue shall be brought in the name of the Government 
8 
of the Philippines and shall be [conducted] INVESTIGATED, 
9 
PROSECUTED AND HANDLED EXCLUSIVELY by legal officers 
10 
of the Bureau of Internal 'Revenue but not civil or criminal action 
11 
for the recovery of taxes or the enforcement of any fine, penalty or 
12 
forfeiture under this Code shall be filed in Court without the 
13 
approval of the Commissioner. FOR THIS PURPOSE, NO 
14 
REFERRAL BY THE BUREAU OF INTERNAL REVENUE TO 
15 
THE 
OFFICE 
OF 
THE 
SOLICITOR 
GENERAL, 
THE 
16 
DEPARTMENT OF JUSTICE OR ANY OTHER GOVERNMENT 
17 
AGENCY SHALL BE ALLOWED IN CONNECTION WITH ANY 
18 
CIVIL OR CRIMINAL ACTION HANDLED BY 
LEGAL 
19 
OFFICERS OF THE BUREAU OF INTERNAL REVENUE. 


THE BUREAU OF INTERNAL REVENUE SHALL HAVE 
2 
THE EXCLUSIVE AUTHORITY TO FILE ANY CIVIL OR 
3 
CRIMINAL CASE DIRECTLY IN THE PROPER COURT FOR 
4 
THE RECOVERY OF TAXES OR ENFORCEMENT OF ANY 
5 
FINE, PENALTY OR FORFEITURE UNDER THIS CODE 
6 
PROVIDED THAT, THE DEPARTMENT OF FINANCE SHALL 
7 
HAVE 
AUTOMATIC 
REVIEW 
OVER, 
AND 
CONDUCT 
8 
PRELIMINARY INVESTIGATION 
IN EVERY CRIMINAL 
9 
COMPLAINT BEFORE IT IS FILED IN COURT. 
10 
SEC. 2. Repeliling Cllluse. - All laws, orders, issuances, circulars, rules and 
11 
regulations or parts thereof, w~ich are inconsistent with the provisions of this 
12 
Act, are hereby repealed or modified accordingly. 
13 
SEC. 3. 
Sepambility Clause. c If any provisions of this Act is declared 
14 
unconstitutional or invalid, other parts or provisions hereof not affected shall 
15 
continue in full force and effect .. 
16 
SEC.4. Effectivity. - This Act shall take effect fifteen days (15) days 
17 
following its publication in at least two (2) newspapers of general circulation. 
18 
Approved, 
2