RR No. 12-2025: Further amending Section 5 of Revenue Regulations No. 3-69, relative to the due process requirement in the service and execution of summary remedies

Summary

RR No. 12-2025 further amends Section 5 of RR No. 3-69 on service of warrants and notices, adding a provision for taxpayers previously identified as Cannot Be Located (CBL) who have resurfaced.

Key points

1. Personal service of the warrant. The Revenue Officer serves the Warrant of Distraint and/or Levy (WDL) personally on the delinquent taxpayer, an authorized representative, or a household member of legal age with sufficient discretion, who signs the receipt portion. For a corporation, it is served on the President, Vice President, Manager, Treasurer, Comptroller or a responsible person who customarily receives correspondence.
2. Constructive service. If the taxpayer refuses to receive or is absent, two credible witnesses who are not BIR employees, preferably barangay officials, sign the receipt portion with a copy of their ID. The duplicate is left at the premises, and a copy is sent by registered mail and/or electronic mail.
3. Resurfaced CBL taxpayers. A taxpayer is resurfaced if they personally appear before any BIR Office, or their whereabouts become known through an informant or other legal means.
4. Simultaneous service. Upon resurfacing, the issued WDL is served together with copies of the served Warrants of Garnishment, Notice of Levy, Notice of Tax Lien, Notice of Encumbrance and other correspondence.

Who is affected

• Delinquent taxpayers served with a WDL
• Taxpayers previously reported and published as CBL who have resurfaced

Deadlines and effectivity

• Issued March 6, 2025

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.