The Philippine Constitution recognizes that property use bears a social function. Government is granted the power to regulate the acquisition, ownership, and disposition of property, subject to the duty of the government to promote distributive justice, and to intervene when the common good so demands. Taxation has played a role in the equitable and progressive distribution of wealth.
The Tax Code provides that no registration of any document transferring real property shall be effected by the Register of Deeds unless the Commissioner has certified and issued a Certificate Authorizing Registration (eCAR) that such transfer has been reported and the taxes, if any, have been paid. The eCAR is also required to record the transfer of shares, bonds or rights in the books of any corporation.
However, a closer look into the eCAR requirement reveals the long recognized symbiotic relationship existing between the state and its taxpayers. Jurisprudence provide that taxes are what we pay for civilized society. In 1999, permanent tax identification numbers (TIN) were mandated due to the need to finance the country’s growing infrastructure requirements and support the poverty alleviation projects of the government. A TIN became mandatory to secure the CAR. By 2003, the One Time Transaction Program (ONETT) was created to ensure timely issuance of CAR and to simplify the documentary requirements and procedures.
The Commissioner recently issued Revenue Memorandum Order No. 17-2026 updating the policies and procedures for ONETT. The Commissioner is observed to have incorporated a policy to keep in line with the International Organization for Standardization (ISO) Quality Management System (QMS).
RMO No. 17-2026 introduces amendments to quality forms, mandatory requirements, policies, and procedures designed to ensure standardization of ONETT processing across all BIR Offices including those under the Large Taxpayers Services (LTS).
Under RMO No. 17-2026, taxpayers will now use updated ONETT 2026 Quality Forms with the prescribed format and paper size (8.5 x 13 inches). These forms include updated Checklist of Documentary Requirements (CDR) for transactions involving sale and donation of real and personal properties. RMO No. 17-2026 also introduced additional forms such as CDR for processing and issuance of ONETT’s computation sheet (OCS) of donation consisting purely of cash, transfer of properties pursuant to Section 40(C)(2) of the NIRC, and the ONETT Team Assignment Sheet.
For the sale or donation of real property and shares of stock, the mandatory requirements to secure the OCS include TIN Verification, one original copy and two copies of the Notarized Deed of Sale/Donation, certified true copy of the title/stock, certified true copies of the tax declaration, certificate of no improvement, if applicable, and two government issued IDs. The checklist recognize options for Antedated Sales and rescinded sales. The taxpayer is required to sign an attestation with consent for data processing. Specific quality forms are created for sales of principal residence, for foreclosure sales, properties under socialized housing programs and community mortgage program. A duly accomplished Cannot be Located (CBL) Verification Slip has been also been added to the requirements for all ONETT transactions.
The processing time for the issuance of the OCS incorporates the terminology found in the Ease of Doing Business Act. “Simple” transactions should not exceed three (3) working dates from receipt of complete documentary requirements, but same day release shall be done for taxpayers who are from far flung areas. Included under this category are transactions involving three or less properties. “Complex” transactions shall not exceed seven (7) working days from receipt of complete documents. Included in this category are transfers of more than three or where the parties do not have a valid TIN. Complex transactions also include those that require an ocular inspection. The Commissioner has also classified as “Highly Technical” all estate transactions and ONETT involving more than twenty (20) stock certificates, properties or parties to the transaction. The processing time for highly technical transactions shall not exceed twenty (20) working days excluding exceptional cases such as merger, property dividends and transactions under Section 40 (C)(2) of the Tax Code.
For the issuance of the eCAR, the checklist requires submission of the filed tax returns, certification fee, loose documentary stamp tax, proof of payment which includes the duly validated bank deposit slip, and the ONETT Computation Sheet approved by an authorized revenue officer. The RMO provides that eCAR processing time shall not exceed seven (7) days from receipt of complete documentary requirements. In line with the ISO QSM, the Commissioner has also listed Key Performance Indicators (KPI) required of the ONETT Processors. Monthly reports and monitoring tools of these KPI have been created to ensure that targets are accomplished and released within the prescribed processing time.
As regards the verification of TIN and CBL Taxpayers, the taxpayer may update or apply for a TIN with the concerned RDO or through the Taxpayer Registration-Related Application (TRRA) or the Online Registration and Update System (ORUS). For processing of ONETT through the eONETT System, the ONETT Officer-of-the-Day (OD) will now review and evaluate the submitted supplication and check the completeness of the documentary requirements uploaded by the taxpayer. The ONETT OD will also check and evaluate the auto-computed OCS and shall stamp the word “USED” and indicate the eCAR Number/s in all copies of proof of payment and the eCAR Number, Date of Issuance and the Name of Signature of the Approving Officer at the bank of the transfer document. Verification of the completeness and accuracy of the corresponding ONETT payments shall be made at the earliest time and not later than three (3) working days from receipt of the proof of payment. This clarifies that the plain 3-day period under RMO No. 12-2025 refers to “working” days.
RMO 17-2026 was issued to ensure consistency, efficiency and effectiveness in the processing of the OCS and ultimately the eCAR. The incorporation of ISO QSM in the RMO is also meant as a tool to improve the quality of management in the Bureau, and to streamline the process to collect further revenue to fund the projects of the government.
This article was first published by BusinessWorld at bworldonline.com. It is only for general informational and educational purposes and is not offered and does not constitute legal advice or legal opinion.
Atty. Gillian Ruth A. Grancho is an associate of the Davao Branch of the Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALAW).
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