Collector vs La Tondena, 5 SCRA 665 (1962) LT is engaged in the business of manufacturing wines and liquor with a distillery in Manila.

It purchases alcohol from Negros Occidental and from Batangas and has been removing this alcohol from the centrals to resp distillery under joint bonds without prepayment of specific taxes. Quantity of alcohol purchased and received-entered into the BIR Official Register Books. In the manufacture of Manila Rum, LR uses as basic materials low test alcohol, purchased in crude form from the suppliers which it re-rectifies or subjects to further rectification or distillation==from this process, losses through evaporation incurs, for which CIR had given resp allowance of not exceeding 7% for said losses. In May 1954, CIR wrote demand letter to LT for payment of specific taxes on alcohol lost by evaporation thu re-rectification or re-distillation from June 1950 to Feb 1954. LT protested and CIR refused to reconsider the assessment. LT appealed to the Conference Staff of the BIR. It was ordered to comply with DOF 213 to deposit of the amount in cash and the balance by a surety bond. LT action to CTA. CTA ordered LT to pay P672.15 by way of specific tax. The amount of P154K which corresponds to the period after January 1951 and up to Feb. 1954, pursuant to RA 592=LT is exempt from liability assessed therefor. CIR appealed to SC. Issue: WON LT should pay the specific tax. Held: No. Sec. 133 of the Tax code states liability shall attach to the susbstance as soon as it is in existence as such, whether it be subsequently separated as pure or impure spirits. However RA 592 took effect on Jan. 1, 1951 which amended 133 deleting the all embracing clause which subjects to tax all kinds of alcoholic substances but only distilled spirits as finished products. This is in harmony with Sec. 129 of the Tax code which states that only the finished product is subject. August 1956, RA 1608 was passed restoring the same clause which was eliminated. From Jan. 1951 to Aug. 1956, the tax on alcohol did not attach as soon as it was in existence as such but on the finished product. In every case of doubt, tax statues are construed most strongly against the government and in favor of the citizens, because burdens are not to be imposed beyond what the statutes expressly and clearly import. The new law should not be given retroactive effect.