Garcia-Marquez examined the spouses’ filed returns for 2007–2025 and joint audited financial statements, including cash balances for 2022–2025 and other-income entries. Particular attachments examined included Duterte’s 2023 BIR Form 2316, her professional/legal-activities registration and signed 2025 statements of management responsibility. The July 30 production included ITRs/VAT returns and attachments from RDO 113A.
Research record
October 8, 2026
Tax records, BIR submissions and legal provisions materially examined during the trial.
Related Documents
Read and verify
An exact document is linked only when a public or privacy-cleared copy is available. Specifically identified unavailable documents remain listed without a substitute download. Transcript citations remain with each record.
Duterte–Carpio tax returns, financial statements and identified attachments
July 30 compliance tables and October 6 BIR summaries
The court and defense examined the July 30 compliance tables and October 6 summaries covering the spouses and identified business entities. The witness explained their annual-return sources, RDO encoding, central-office review and additions, including non-taxable-income/final-tax columns. Annex A supplied the spouses’ combined net-income total.
BIR certification on Manases Carpio’s Cale88 share-transfer records
BIR certification
Not available in the Senate document archive.Garcia-Marquez read a certification issued in compliance with the October 1 subpoena, reporting no BIR database record of a transfer/sale/disposition of Carpio’s Cale88 Foods Corporation shares or related tax payments, assessments or settlements. She also answered questions about eCAR issuance and applications.
July 29, 2026 Executive Secretary memorandum authorizing BIR production
Presidential authorization memorandum
Not available in the Senate document archive.Ferrer quoted the memorandum authorizing inspection by, and original/certified copies and electronic records for, the Senate Impeachment Court. The hearing disputed whether that authorization extended to public display.
Sara Duterte’s 2025 Statement of Assets, Liabilities and Net Worth
SALN
Not available in the Senate document archive.Matib compared the spouses’ combined income with the 2025 SALN net-worth figure of ₱98,656,131.20.
BIR Revenue Memorandum Circular 37-2012
BIR circular
Matib requested display of RMC 37-2012 and the witness read the cited rule requiring tax payment before stock-transfer registration and the reporting duty of the stock-transfer agent or corporate secretary.
Articles of Impeachment—Article II
Articles of Impeachment
Matib’s offer linked income, professional-income, asset and business-interest allegations to Article II. The court limited earlier-year evidence to baseline or pattern.
1987 Constitution—Article VII, Sections 6 and 13
Constitution
The witness read the provisions on emoluments and outside professional/business activity after counsel requested their display. The provisions were used in the professional-income exchange.
Local Government Code—Section 90(a)
Statute
Matib requested and Garcia-Marquez read Section 90(a) on governors’ and city/municipal mayors’ professional practice or other occupation outside executive functions, following discussion of the 2021 mayoral period.
Data Privacy Act and its implementing rules
Statute and implementing rules
Ferrer invoked the Act’s sensitive-personal-information definition in opposing public display of tax returns. Matib invoked Act Section 16(b) and IRR Section 22(f) as stated in court in response.
National Internal Revenue Code—Section 71
Statute
Ferrer invoked Section 71 on inspection of returns when distinguishing presidential authorization for court access from public viewing. The linked 1997 Code text contains the identified provision.
Revised Rules on Evidence—Rule 132, Section 19
Rules of evidence
The court cited Rule 132, Section 19 when classifying the BIR-held documents as public records and preserving challenges to authenticity, execution and custody.