CHAPTER 1- NATURE AND PRINCIPLES OF TAXATION

LEARNING OBJECTIVES:

TAXATION DEFINED

As a state power- it refers to the inherent power of a sovereign state acting through its legislature to impose a
proportionate burden upon persons, property rights, or transaction to raise revenue to support government
expenditure and as a tool for economic welfare.

As a process- it refers to the act of imposing a tax by a sovereign state to raise revenue for the use of the government.

PURPOSES OF TAXATION

Primary Purpose- to raise revenue/ funds for the expenses of the government (also called Revenue purpose).
Basically, the purpose of taxation is to provide funds or property with which the state promotes the general welfare
and protection of its citizens.

Secondary Purpose- as a tool for general social and economic welfare (also called
Regulatory/Sumptuary/Compensatory Purpose)
A. Regulation- in the case of taxes levied on exercises or privileges like those imposed on tobacco and alcoholic
products or amusement places like night clubs, cabarets, cockpits etc.

B. Promotion of General Welfare- in one decided case, the supreme court ruled that taxation may be used as to
implement police power in order to promote generate welfare of the people.

C. Reduction of Social Inequality- this is made possible through the progressive system of taxation where the objective
is to prevent the undue concentration of wealth in the hands of few individuals.

D. Encourage Economic Growth- the purpose is to grant incentives or exemptions to encourage investments and
hereby promote the country’s economic growth.

BASIS OF TAXATION (Banggawan, 2021)

The government provides benefits to the people in the form of public services and the people to provide the funds that
finance the government. This mutuality of support between the people and the government is referred to us the BASIS
of TAXATION.

Roxas & Valencia (2020, p1-2) explains the ff. Inherent Powers of the State.

INHERENT POWERS OF THE STATE

“The sovereign state is born and will exist continuously with essential powers necessary for its survival. These powers
are called “Inherent powers” because they exist as the central force in order that a government can command,
maintain peace and order, and survive, irrespective of any constitutional provision.”

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 INHERENT
POWERS OF
THE STATE

Police Power Eminent Domain Taxation Power

The power to protect Power The power to enforce
citizens and provide for The power to take private contributions to support
safety and welfare of property (With just the government, and other
society compensation for public inherent powers of the
use) state

THE POWER TO TAX

Subject to inherent and constitutional limitations, the power of taxation is regarded as supreme, plenary,
unlimited, and comprehensive.1 As long as the legislature, in imposing a tax, does not violate applicable
constitutional limitations or restrictions, the courts have no concern with the wisdom or policy of the
exaction, the political or other collateral motives behind it, the amount to be raised, or the persons,
property, or other privileges to be taxed.2

NATURE OF POLICE POWER

“Police Power refers to the inherent power of the sovereign state to legislate for the protection of health, welfare and
morals of the community. It is exercised usually to guard against excesses or abuses of the individual liberty.”

“This process is restricted by the “due process clause” of the constitution which provides that no person shall be
deprived of life, liberty or power without due process of law.”

“Examples of Police Power are Preservation of natural resources, segregation of lepers from the public, imprisonment
of convicted criminals, and regulation of the various professions.”

NATURE OF EMINENT DOMAIN

“Eminent Domain refers to the power of the sovereign state to take private property for a public purpose. It is founded
upon the idea that the common necessities and interests of the community transcend individual rights in property.”

“Consequently, the state may expropriate private property when it is necessary to promote general welfare. Since
eminent domain is inherent in sovereignty, pertinent provisions in the constitution are not grants of the power, but
rather limitations upon its exercise.”

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DISTINCTIONS AMONG THE THREE INHERENT POWERS

A) Purpose:

Taxation To raise revenues for the expenses of the State.

Police Power To promote the general welfare thru regulations.
Eminent Domain To facilitate the State’s need of property for public use.

B.) Amount of Exaction

Taxation No limit.
Police Power Limited to the cost of regulation, issuance of the license, and/or
surveillance.
Eminent Domain No exaction but private property is taken for public use.

C. Benefits Received

Taxation No special or direct benefit is received by an individual

taxpayer. The public receives the general benefit of
protection of person, property and the promotion of
the general welfare.
Police Power No direct benefit is received by an individual. A
healthy economic standard of society is attained.
Eminent Domain A direct benefit results in the form of just
compensation to the property owner.

D.) Non-Impairment of Contracts

Taxation Obligations in contracts may not be impaired by the state

where tax exemptions are bilaterally agreed upon by the state
and the taxpayer. Tax exemptions bilaterally agreed upon
between the government and the taxpayer cannot be
withdrawn.
Police Power Obligations in contracts may be impaired by the government.
Eminent Domain Obligations in contracts may be impaired by the government.

E. Transfer of Property Rights

Taxation Taxes paid become part of public funds.

Police Power No transfer, but only restraint in the exercise of property rights.
Eminent Domain Transfer is effected in favour of the State.

F. Scope

Taxation All persons, property, rights, and privileges.

Police Power All persons, property, rights, privileges, and liberties
Eminent Domain Only upon specific property.

G. Authority which exercises the power

Taxation Exercised by the government or its political

subdivisions

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 Police Power Exercised by the government or its political subdivisions
Eminent Domain May be exercised by public service corporations or private
entities operating public utilities if granted by law

STAGES OR COVERAGE OF TAXATION

Taxation covers three (3) separate areas or aspects of government activity, namely:

1. Levying or imposition of the tax. This involves the passage of tax laws which is generallya
legislative act. In the Philippines, the taxing power is exercised by Congress.

2. Assessment. The process of determining the correct amount of tax due.

3. Collection and payment – the act of compliance with the tax law by the taxpayer.

Executive or administrative in nature. Done by the Bureau of Internal Revenue (“BIR”)

THEORIES OF COST ALLOCATION (Banggawan, 2021)

Taxation is a mode of allocating government costs or burden to the people. In distributing the costs or burden, the
government regards the following general considerations in the exercise of its taxation power.

1. Benefit Received Theory- presupposes that the more benefit one receives from the government, the more taxes
he should pay.

2. Ability to Pay Theory- presupposes that taxation should also consider the taxpayer’s ability to pay. taxpayers
should be required to contribute based on their relative capacity to sacrifice for the support of the government.

In short, those who have more should be taxed more even if they benefit less from the government. Those who
have less shall contribute less even if they receive more of the benefits from the government.

THE LIFE BLOOD DOCTRINE

Taxes are essential and indispensable to the continued subsistence of the government. Without taxes, the government
would be paralyzed for lack of motive power to activate or power it.

Taxes are the lifeblood of the government, and their prompt and certain availability are an imperious need. upon
taxation depends on the government’s ability to serve the people for whose benefit taxes are collected. (Banggawan,
2021)

Roxas & Valencia (2020, p 33) explains the Essential Characteristics of Taxes.

a.) Enforced Contribution- the imposition shall not be dependent upon the will of the taxpayer.
b.) Imposed by a Legislative Body- the congress makes tax laws.
c.) Proportionate in Character- the “ability to pay principle: is the basic rule in collecting taxes. Those who earn
more, contributes more than those who earn lesser.
d.) Payable in the form of money- Money is the preferred payment of taxes. If property is taken to satisfy a tax
liability, the property is sold through public auction to satisfy the tax obligation.
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 e.) Imposed for the purpose of raising revenue- taxes are the primary source of government funds to finance its
expenditures and projects.
f.) Used for a public purpose- money is taken from the public so it can be returned to them in the form of
public benefits.
g.) Enforced on some persons, properties or rights- objects of taxation are either tangible or intangible
properties, including business transactions.
h.) Commonly required to be paid at regular intervals- the dates for paying of taxes are fixed by law to comply
with the principle of administrative feasibility.
i.) Imposed by the sovereign state within its jurisdiction- the enforcement of tax is subject to territorial
jurisdiction and international comity.

LIMITATIONS ON POWER OF TAXATION

a.) Constitutional- limitations which are found in the constitution

b.) Inherent- limitations which are not found in the constitution

INHERENT LIMITATIONS
a.) Levied for Public Purpose- it is the first requisites of lawful taxation that the purpose for which it is laid shall
be a public purpose.
b.) Exemption of the Government from Taxes- property of the state and of its political subdivisions is devoted to
government uses and purposes is generally deemed to be exempt from taxation
c.) Non-Delegation of legislative power to tax- in the distribution of the powers of government into three
departments, namely, legislative, executive and judicial, the power of taxation is exclusively legislative.
Consequently, the taxing power as a rule may not be imposed.

Note: Certain notable exceptions to non delegability

- Imposed the constitution, congress may expressly authorize the president to fix within specified limits
and subject to such limitations and restrictions as it may impose, tariff rates, import and export quotas,
tonnage, wharfage dues, and other dues or imposts within the framework of the national development
program of the government.
- Another exception is in the case of the local taxing power. Each local government unit shall have the power
to create its own sources of revenues and to levy taxes, fees and charges subject to such guidelines and
limitations as the congress may provide, consistent with the basic policy of local autonomy.
d.) Territoriality or the Situs of Taxation- which means “place of taxation” is a limitation on the taxing power. Such
power is necessarily limited only to person’s property or business within its jurisdiction. This literally means
place of taxation, to the country that has the jurisdiction to levy a particular tax on persons, property, or rights.
The following are the basis of the situs of taxation of the different tax objects or subjects.

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 Situs of Persons
-For Community- tax residence of person
-For Income Tax- either citizenship, residence or source of income
-For Estate Tax- residence of the decedent at the time of death
-For Donor’s Tax- residence of donor at the time of donation
-For Business/ Occupation’s Tax- Place of Business. Sale, or practice profession or occupation
Situs of Property
-If real property- location of property
-If tangible personal property- location of the property or the owner’s domicile
-If Intangible Personal property- domicile or residence of the owner
e.) International Comity- more often than not, states fined it mutually advantageous for themselves to create self-
imposed restraints on their taxing powers especially with reference to the properties of foreign governments
within their territorial domain.

CONSTITUTIONAL LIMITATION

a.) Due Process of Law

Article III Section 1 of the Constitution provides that “No person shall be deprived of life, liberty, or property
without due process of law, nor shall any person de deny the equal protection of the laws.”
- The phrase “due process of law” mandates a fundamental right of protection that life , liberty or property
shall only be taken away from any person ( natural or juridical) if its exercise is not contrary to the
fundamental law of the land and it is done after compliance with the established procedure established by
law.
- Due process requires giving notice to the taxpayer, providing him hearing, so as to be given fair
opportunity to assert his substantial rights before a competent court before he shall be denied or deprived
of his property of non payment of tax.
- Essentially, due process requires that the law should be reasonable and not oppressive (substantive) and
it requires opportunity to be heard in proper court of litigation before judgment is rendered affecting
one’s person or property.
- The purpose of due process of law is to secure the individual from the abusive exercise of the taxing power
of the government. This prevents the latter to encroach against the life, liberty and property of individual
persons, and thus protect property from confiscation without proper trial.

b.) Equal Protection of Law

- Equal protection of law means that all persons subject to legislation shall be treated alike under similar
circumstances and conditions both in the privileges conferred and liabilities imposes. The purpose of this
constitutional mandate is to protect persons belonging to the other same class against intentional and
arbitrary discrimination.

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 - There is denial of equal protection of laws, if there is discrimination in the implementation of tax laws. For
instance, a tax ordinance applicable to similar persons, firms or corporations in the same class which are
subject to the same rate are taxed impartially imposing the ordinance to some and favouring the others.

c.) Rule of Uniformity and Equity in Taxation

Article VI, Section 28, par.1 of the Constitution states that “The rule of taxation shall be uniform and
equitable. Congress shall evolve a progressive system of taxation .”
A tax is said to be uniform in application if it operates with the same force and effect in every place
where the subject may be found, not when it singles out one particular class for taxation or exemption.
-“ Equality in Taxation” is similar to progressive system of taxation, the tax laws and their implementation
must be fair, just, reasonable and proportionate to one’s ability to pay.
-The primary requisite of equity principle is that a progressive tax rate shall be applied equally to all
persons, firms, and corporations and transactions placed in similar classification and situation.
- The progressive system of taxation means that the tax laws shall give emphasis on direct rather than
indirect taxes or on the ability to pay principle of taxation. An example of this kind is the current individual
income tax system that imposes rates progressing upwards as the tax base (tax payers taxable income increases)

d.) President’s Veto Power

“Article VI, Section 27, par.2 of the Constitution states that “Every bill passes by the congress shall, before it
becomes a law be presented to the president. If he approves the same, he shall sign it; otherwise, he shall veto it and
return the same with his objections at large in its journal and proceed to reconsider it…...”
“Veto power refers to the executive’s power to refuse to sign into law a bill that has been passed by a
legislature, it can be classified into (a) item veto- the power to veto items in appropriation bills without affecting
any other provisions of such bills, and (b) Pocket Veto- the power to disapprove legislative act by the President
with the result that bills shall fail to become laws.”
“The president shall communicate his veto of any bill to the House where it originated within thirty days after
the date of receipt thereof; otherwise, it shall become a law as if he had signed it.”
“If the president vetoed the bill, two thirds of the members of the House are required to make such bill to
become a law.”
e.) Exemption from Property Taxation
“Article VI, Section 28, par.3 of the Constitution states that “Charitable Institutions, churches, parsonages or
convents appurtenant thereto, mosques and non-profit cemeteries and all lands, buildings, and improvements
actually, directly and exclusively used for religious charitable or educational purposes shall be exempt from
taxation..”
“This exemption is granted to them in return for the benefits they have afforded to the public welfare.”
“The supreme court, however, held that such tax exemption for the above provision should be applicable
only to real property taxes and not to transfer taxes. Hence if a land owned by a religious order is sold, it is subject
to final tax of 6% based on the selling price or fair market value whichever is higher.”
“To be exempted from taxation, the real property must be exclusively used for religious, educational
and charitable purposes.”
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 “It would appear, therefore that “idle lands” or property used by others for other purposes although
owned by religious, educational and charitable institutions could be subjected to real property tax.”
“For this reason, the issue of ownership is not relevant, as long as the real property is used for religious,
educational, and charitable purposes in which case such property shall be exempted from real property tax.”
Art XIV, Sec 4, par. 3 of the Philippine Constitution states that “ All revenues and assets of the non-stock,
non profit educational institutions used actually, directly and exclusively for educational purposes shall be
exempted from taxes and duties.”
“Proprietary educational institutions, including those cooperatively owned, may likewise be entitled to
such exemptions subject to the limitations provided by law including restrictions on dividends and provisions
for reinvestment.”
f.) No public money shall be appropriated for religious purposes
“Article VI, Section 29 of the Constitution states that “No public money or property shall ever be
appropriated, applied, paid or used directly or indirectly for the use, benefit, or support of any sect, church,
denomination, sectarian, institution, or system of religion or for the use, benefit or support of any priest,
preacher, minister or other religious teacher or dignitary as such, except when such priest, preacher,
minister, or dignitary is assigned to the armed forces, or any penal institution, or government orphanage or
leprosarium .”
“In concurrence with the constitution, the state shall have no official religion or shall not set up a church,
whether or not supported with public funds or prefer one religion over another.”
“Likewise, the church should not interfere in purely political matters or affairs exclusively for the state.
Consequently, the constitution prohibits against infringement of religious freedom.”
g.) Majority of all the members of the congress granting tax exemption
“Article VI, Section 28, par 4 of the Constitution provides that “No law granting any tax exemption shall be
passed without the concurrence of a majority of all the members of the congress.”
“It shall be observed that the above constitutional provision requires the concurrence of a majority not of the
attendees constituting a quorum but of all the members of the congress.”
“Article VI, Section 24, of the Constitution provides that “all appropriation, revenues or tariff bills
authorizing increase of the public debt, bills of local application and private bills shall originate exclusively in
the House of Representatives, but the senate may proposes or concur with amendments.”
h.) Supreme Court’s Final Judgment in all Tax cases
“Article VIII, Section 5, par 2 (b) of the Constitution provides that “ the supreme court shall have the
power to review, revise, reverse, modify or affirm on appeal or certiorari, as the laws or the rules of court may
provide, final judgments and orders of lower courts in all cases involving the legality of any tax, impost,
assessment, or toll or any penalty imposed in relation thereto.”
“The power of judicial review in taxation is limited only to the interpretation and application of tax laws. The
judicial tribunals have no concern on the wisdom of taxing act. Its power does not include inquiry on the policy of
legislation. Neither can it legitimately question or refuse to sanction the provisions of any law consistent with the
constitution.”
i.) No Imprisonment for Non- payment of Poll Tax

“Article III, Section 20, of the Constitution provides that “No person shall be imprisoned for debt or non-
payment of a poll tax.”
“The term “poll tax” means a tax imposed on a person as a resident within a territory of the taxing authority
without regard to his property, business or occupation. A good example of a poll tax is community tax.”
“It is to be noted that the prohibition of imprisonment applies only to the non-payment of poll tax.
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 Consequently, imprisonment fro non payment of other taxes (not poll in nature) or imposition of
fine would not be contrary to the constitution.”

J.) Tax collection shall generally be treated as general funds of the government
“Article VI, Section 29, par. 3 of the Constitution states that “All money collected of any tax levied for a special purpose
shall be treated as a special fund and paid out for such purpose only, if the purpose for which a special fund was
created has been fulfilled or abandoned, the balance, if any, shall be transferred to the general funds of the
government.”

“Thus collection of fee with the nature of taxes intended for the promotion of sugar industry shall be treated as a
special fund, such fund shall be used for its intended purpose and none of its part shall be used for exclusive benefit of
any private person. Once the purpose is achieved, the unspent amount shall be transferred to the general fund
of the government.”

BASIC PRINCIPLES OF SOUND TAX SYSTEM

1. Fiscal Adequacy – which means that the sources of revenue should be sufficient to meetthe
demands of public expenditures.

2. Equality or Theoretical Justice – which means that the tax imposed should be
proportionate to the taxpayer’s ability to pay; and

3. Administrative Feasibility – which means that the tax laws should be capable ofconvenient,
just, and effective administration

CLASSIFICATION OF TAXES

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 -

NATURE OR CONSTRUCTION OF TAX LAWS

1. Tax laws are prospective, generally, but can have retrospective application.

The constitutional prohibition against the passage of laws having retrospective application
(also called ex post facto legislation) is limited to penal or criminal statutes.

Tax laws are not penal in character. Being civil in nature, the constitutional prohibition
against ex post facto legislation does not apply to tax laws. 20 They can therefore be given
retrospective application if expressly declared by the tax law.

However, tax laws, like other statutes, are to be construed as having only a prospective
operation unless the purpose and intention of the legislature to give retrospective effect is
expressly declared or is necessarily implied from the language used.21

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 A tax creates a civil obligation or liability on the part of the taxpayer,
although the non- payment thereof creates a criminal liability, which could
be the subject of criminal prosecution under existing laws. In short, in
taxation, it is one’s civil liability to pay taxes that gives rise to criminal
liability.22

2. A statute will not be construed as imposing a tax unless it does

so clearly, andunambiguously.

3. Tax exemptions are to be construed strictly against the taxpayer.

Legal provisions providing for tax exemptions are to be construed strictly

against the grantand liberally in favor of the taxing power.25

Exemption from taxation is construed strictissimi juris, i.e. strictly against

exemption. Hence, exemption must be anchored firmly on an express
provision of law. He who claimsexemption must be able to justify his claims
by the clearest grant of organic and statute law.26

4. Revenue laws are not political in nature.

Our internal revenue laws are not political in nature and as such were
continued in force during the period of enemy occupation and in effect
were actually enforced by theoccupation government.27

5. Legislative intention must be considered. Tax statutes are to receive a

reasonable construction with a view to carrying out their purpose and
intent.28

6. Tax laws are special laws and prevail over general laws.29

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 SOURCES OF TAX LAWS

1. The 1987 Constitution.

2. Tax statutes such as the National Internal Revenue Code (“NIRC”), the Tariff
and Customs Code, the VAT Law, the Revised Documentary Stamp Tax Law,
the Amended Excise TaxLaw, and portions of the Local Government Code.
3. Executive orders on taxation, and local tax ordinances.
4. Tax treaties and conventions with foreign countries.
5. Judicial decisions.
6. Rules and regulations promulgated by the Department of Finance, the
Bureau of InternalRegulations (“BIR”), Bureau of Customs, etc.
7. Administrative interpretations and opinions of tax officials particularly
those of theCommissioner of Internal Revenue.
FORMS OF ESCAPE FROM TAXATION

1. Shifting the burden of the tax.

2. Capitalization. By not selling property which has increased in value, the

owner avoids the income tax to be paid on the gain if the same is sold. An
increase in the value of an asset is merely an unrealized increase (gain) in
capital.

3. Transformation. The manufacturer or producer upon whom the tax has

been imposed, fearing the loss of his market if he should add the tax to the
price, pays the tax. He then endeavors to recoup the tax paid by making his
production more efficient and lowering hiscost of production.

4. Tax exemption. Exemption from taxation is the freedom from the burden of paying
tax.

5. Tax avoidance (Tax Minimization). Tax avoidance occurs when the means
used to minimize taxes are legaland not prohibited by law.

6. Tax evasion ( Tax Dodging). Tax evasion connotes fraud through the use
of pretenses and forbiddendevices to lessen or defeat taxes.30

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CERTAIN DOCTRINES IN TAXATION
“In the exercise of taxation power, some underlying doctrines for its implementation are as
follows:”
1. Prospectivity of Tax Laws

“The principle of “Prospectivity of Tax Laws” states that a tax bill must only be applicable
and operative after becoming a law. Thus, the effectivity of the tax law commences upon its
approval and its scope would only cover the present and future transactions.”
“The retroactive application of tax laws shall not be applied unless there is a clear intent of the
legislature that such law shall also be imposed on past transactions.”
2. Imprescriptibility of Taxes

“The rule on “tax imprescriptibility” states that unless otherwise provided by the tax law itself,
taxes in general are not cancellable.”
“Although the tax code provides for the limitation in the assessment and collection of taxes
imposed, such prescriptive period will only be applicable to those taxes that were returnable.
The prescriptive period shall start from the time the taxpayer files the tax return and
declares his tax liability.”
“The court held that there is no time limit on the right of the BIR Commissioner to assess taxes
on unreasonable accumulated earnings of the corporation.”
3. Double Taxation

- It occurs when the same taxpayer is taxed twice by the same tax jurisdiction for the same
thing. (Banggawan, 2021)
ELEMENTS OF DOUBLE TAXATION

1. Primary Element: Same Object

2. Secondary Elements:
a. Same type of tax
b. Same purpose of tax
c. Same taxing jurisdiction
d. Same tax period

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 TYPES OF DOUBLE TAXATION

1. Direct Double Taxation

This occurs when all the element of double taxation exists for both impositions
Examples:
a. An income tax of 10% on a monthly sale and aa 2% income tax on the annual sales
(Total of monthly sales)
b. a 5% tax on bank reserve deficiency and another 1% penalty per day because of such
reserve deficiency.
2. Indirect Double Taxation
This occurs when at least one of the secondary elements of double taxation is not
common for both impositions.
Examples:
a. The national government levies business tax on the sale or gross receipts of
business while the local government levies business tax upon the same sales or
receipts.
b. The national government collects income tax from a taxpayer on his income while
the local government collects community tax upon the same income.

Note: Nothing in our law expressly prohibits double taxation. In fact, indirect double taxation
is prevalent in practice. However, double direct taxation is discouraged because it is
oppressive and burdensome to taxpayers. It is also believed to counter the rule of equal
protection and uniformity in constitution.

How to Counteract Indirect Double Taxation?

Indirect Double Taxation may be counteracted through the application of:
1. Tax Exemption

2. Tax Credit

3. Allowance for deduction such as vanishing deduction in estate tax

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 TAX AMNESTY vs. TAX CONDONATION (Banggawan, 2021)

1. Tax Amnesty
- It is a general pardon granted by the government for erring taxpayers to give them a
chance to reform and enable them to have a fresh start to be a part of society with a clean
slate. It is an absolute forgiveness or waiver by the government on its right to collect and
its retrospective in application.
- Amnesty covers both civil and criminal liabilities
- Amnesty operates retrospectively by forgiving past violations
- Amnesty is also conditional upon the taxpayer paying the government a portion of tax

2. Tax Condonation
-Is forgiveness of the tax obligation of a certain taxpayer under certain justifiable grounds.
This is also referred to as tax remission. Because they deprive the government of
revenues, tax exemption, tax refund, tax amnesty, and tax condonation, are construed
against the taxpayer, and in favor of the government.
-covers only civil liabilities
- Applies prospectively to any unpaid balance of the tax hence, the portion already paid by
the taxpayer will not be refunded.
-Requires no payment

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REFERENCES:

Banggawan, Rex (2021). Income Taxation: Laws, Principles and Applications. Baguio City

De Vera Jack. (2021). Quicknotes in Taxation. Manila

Reyes, Virgilio. (2021). Taxation. Manila Philippines

Tabag, Enrico and Garcia, Earl James (2021). Income Taxation. Quezon City Philippines

The harder you work for something, the greater you’ll feel when you achieve it.

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