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Question
Riviera Plastics, Inc. (Riviera), a corporate taxpayer, receives a deficiency assessment from the BIR for 2024 in the amount of PHP 60,000,000 (exclusive of interest and penalties). Riviera has a currently collectible receivable of PHP 65,000,000 from its customer, Oceanic Components, Inc., arising from a long-standing contract. In a single transaction, Oceanic withholds PHP 60,000,000 from a payment due to Riviera and remits that amount directly to the BIR to satisfy Riviera’s tax deficiency, arguing that private set-off with a tax debt should be allowed. The remainder of the receivable (PHP 5,000,000) remains with Oceanic to be paid to Riviera, and Riviera’s tax liability is deemed settled to the extent of the withheld amount. The BIR refuses to recognize a private set-off against a tax liability, citing the Lifeblood Doctrine. In light of the Lifeblood Doctrine, address: (a) whether Oceanic’s withholdings and remittance to the BIR constitute a valid private set-off against Riviera’s tax debt; (b) the implications of the Lifeblood Doctrine for private compensation and set-off in tax collection; and (c) the impact on Oceanic as a third party and the proper remedy for Riviera. Include the controlling rule, apply it to the facts, and state a concise conclusion.