— Nature and extent of tax lien.
Section 315
SEC. 315. — Nature and extent of tax lien.—If any person, corporation, partnerships, joint-account (cuenta en participation), association, or insurance company liable to pay an internal revenue tax, neglects or refuses to pay the same after demand, the amount shall be a lien in favor of the Government of the Philippines from the time when the assessment was made by the Commissioner of Internal Revenue until paid, with interest, penalties, and costs that may accrue in addition thereto upon all property and rights to property belonging to the tax payer: Provided, That this lien shall not be valid against any mortgagee, purchaser, or judgment creditor until notice of such lien shall be filed by the Commissioner in the office of the register of deeds of the province or city where the property of the taxpayer is situated or located.