Davao: The Court of Tax Appeals (CTA) has dismissed a petition filed by the popular local food manufacturer, Dole Philippines Inc.-Stanfilco Division, which challenged an environmental tax imposed by the city government of Davao.

According to Philippines News Agency, the decision, penned by Associate Justice Corazon Ferrer Flores on March 11, saw the CTA's special second division dismiss the petition for review due to lack of jurisdiction. The case was escalated to the tax court after Dole Philippines sought a reversal of the Davao City Regional Trial Court (RTC) Branch 17's decision to enforce the environmental tax.

The tribunal clarified that the primary objective of the Davao City ordinance is to protect, conserve, and manage the watershed. It emphasized that the fees imposed are primarily regulatory in nature rather than revenue-raising. The court mentioned, "In sum, the Environmental Tax imposed by respondents pursuant to Article 17 of Davao City Ordinance No. 0310-07 is not a local tax, for purposes of Section 7(a)(3) of RA (Republic Act) No. 1125, as amended by RA No. 9282. Correspondingly, this Court is without jurisdiction to entertain the present appeal of the assailed Decision and Order issued by the Court a quo."

Additionally, the court highlighted that jurisdiction is a matter of substantive law, and an action may only be filed with the commission or tribunal designated by the Constitution or a statute. The CTA stated that objections to jurisdiction cannot be waived and may be raised at any stage of the proceedings, even on appeal. "When a case is filed with a court which has no jurisdiction over the action, the court shall motu proprio dismiss the case," it added.