4/7/2021 E-Library - Information At Your Fingertips: Printer Friendly adds, moreover, that the petition does not meet the requirements of Rule 65 for actions for prohibition since the BIR did not exercise judicial, quasijudicial, or ministerial functions when it sought to impose VAT on toll fees. Besides, petitioners Diaz and Timbol has a plain, speedy, and adequate remedy in the ordinary course of law against the BIR action in the form of an appeal to the Secretary of Finance. But there are precedents for treating a petition for declaratory relief as one for prohibition if the case has far-reaching implications and raises questions that need to be resolved for the public good. The Court has also held that a petition for prohibition is a proper remedy to prohibit or nullify acts of executive officials that amount to usurpation of legislative authority. Here, the imposition of VAT on toll fees has far-reaching implications. Its imposition would impact, not only on the more than half a million motorists who use the tollways everyday, but more so on the government's effort to raise revenue for funding various projects and for reducing budgetary deficits. (Emphasis supplied) Here, RR 15-2013 greatly impacts the Philippine maritime industry since it is considered "as more of the 'backbone' of the Philippines' burgeoning economy due to its significance both for trade and transportation."[49] For this reason and the fact that the issue at hand has already pended since 2013 or for more than six (6) years now, first with the trial court and now with this Court, we resolve to treat the present case as one for certiorari or prohibition and settle the controversy once and for all. Diaz aptly enunciated: Although the petition does not strictly comply with the requirements of Rule 65, the Court has ample power to waive such technical requirements when the legal questions to be resolved are of great importance to the public. The same may be said of the requirement of locus standi which is a mere procedural requisite. (Emphasis supplied) RR 15-2013 is a valid issuance In treating demurrage and detention fees as regular income subject to regular income tax rate, the Secretary of Finance relied on Section 28(A)(I)(3a) of the NIRC, as amended by RA 10378, viz.: SEC. 28. Rates of Income Tax on Foreign Corporations. — (A) Tax on Resident Foreign Corporations. — (1) xxx (2) xxx (3). International Carrier.—An international carrier doing business in the Philippines shall pay a tax of two and one-half percent (2 1/2 https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65912 15/25