(1) Planters Products, Inc. and Fertiphil Corporation both import and distribute fertilizers in the Philippines. President Marcos issued LOI 1465 imposing a P10 capital recovery component on every bag of fertilizer sold domestically. The funds collected were remitted to Planters Products to make the company viable. (2) Fertiphil paid over P6 million in levies under protest and demanded a refund after LOI 1465 was no longer enforced. When Planters Products refused, Fertiphil filed a collection case arguing LOI 1465 was unconstitutional. Both the RTC and CA ruled in Fertiphil's favor, finding the levy solely benefited a private entity.