R.A.

9504(TAXEXEMPTIONOFMINIMUMWAGEEARNERSANDINCREASINGPERSONAL/ADDITIONAL
EXEMPTIONS / CHANGE IN Optional Standard Deduction) must beliberally construed. We are
mindful of the strict construction rule when it comes to the interpretationof tax exemption
laws. The canon, however, is tempered by several exceptions, one of which is whenthe
taxpayer falls within the purview of the exemption by clear legislative intent. In this
situation, therule of liberal interpretation applies in favor of the grantee and against the
government. In this case,there is a clear legislative intent to exempt the minimum wage
received by an MWE who earnsadditional income on top of the minimum wage. As previously
discussed, this intent can be seen fromboth the law and the deliberations. Accordingly, we
see no reason why we should not liberallyinterpret R.A. 9504 in favor of the taxpayers.(JAIME
N. SORIANO VS. SECRETARY OF FINANCE ANDTHE COMMISSIONER OF INTERNAL REVENUE,
G.R. NO. 184450, JANUARY 24, 2017, C.J.SERENO)