Case Digest (G.R. No. L-9637) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In American Bible Society v. City of Manila, the American Bible Society, a foreign non-stock, non-profit religious missionary corporation established in the Philippines since 1898 with its principal office at 636 Isaac Peral, Manila, was summoned on May 29, 1953 by the Acting City Treasurer for conducting the business of general merchandise—namely, distributing and selling Bibles and gospel portions—without a Mayor’s permit and municipal license in violation of Ordinance No. 3000, as amended, and Ordinances Nos. 2529, 3028, and 3364. The Treasurer demanded payment of P5,821.45 for unpaid license fees from the fourth quarter of 1945 to the second quarter of 1953 plus compromise penalties. To prevent closure of its operations, the Society paid under protest P5,891.45 on October 24, 1953 and immediately filed suit praying for the ordinances’ annulment and a refund with interest. The trial court, relying on Section 2444(m-2) of the Revised Administrative Code and its substantive ree Case Digest (G.R. No. L-9637) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Plaintiff-Appellant: American Bible Society
- Foreign, non-stock, non-profit, religious missionary corporation.
- Philippine agency established in Manila (Nov. 1898), principal office at 636 Isaac Peral.
- Defendant-Appellee: City of Manila
- Municipal corporation under Republic Act No. 409 (Revised City Charter).
- Business Activity and Treasury Demand
- The Society distributed and sold Bibles and gospel portions (translated into local dialects) throughout the Philippines (except during Japanese occupation).
- On May 29, 1953, the Acting City Treasurer notified the Society that it was conducting “general merchandise” sales without the required Mayor’s permit and municipal licenses under Ordinances Nos. 3000 (as amended), 2529, 3028 and 3364.
- The Treasurer demanded payment, within three days, of permit and license fees (4th Q 1945 to 2nd Q 1953) totaling ₱5,821.45, plus a ₱70 compromise, for a grand total of ₱5,891.45, to be deposited under protest before filing suit.
- Protest Payment and Complaint
- On October 24, 1953, the Society paid ₱5,891.45 under protest and filed suit the same day.
- Prayer for relief: declaration that the ordinances are illegal and unconstitutional; refund of ₱5,891.45 with interest; costs.
- Pleadings and Stipulation
- Defendant’s Answer: ordinances validly enacted under R.A. 409 § 18(1)(o) and former Adm. Code § 2444(m-2); requested dismissal.
- Stipulated Facts: quarterly sales figures from 4th Q 1945 to 1st Q 1953; right to present additional evidence reserved.
- Trial Evidence
- Proof of continuous existence since 1899; tax-exempt real properties; no pre-war license requirement; no sales tax in the U.S.
- Society’s sale prices sometimes exceeded cost but it claimed no profit motive and relied on remittances and voluntary contributions.
- Lower Court Decision and Appeal
- Trial Court: held the ordinances valid and applicable; dismissed the complaint with costs.
- Society appealed; Court of Appeals certified the case to the Supreme Court on issues of law.
Issues:
- Whether Ordinances Nos. 3000 (as amended), 2529, 3028 and 3364 are constitutional and valid under the Revised Municipal Charter and the Constitution.
- Whether those ordinances, in their application, lawfully cover the American Bible Society’s distribution and sale of Bibles and religious literature.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)