Case Digest (G.R. No. 28863)
Facts:
The case involves Batangas Transportation Co. as the plaintiff and the Provincial Treasurer of Batangas, the Municipal Council of Batangas, and the Municipal Treasurer of Batangas as defendants. The events leading to the case began on June 20, 1924, when the Municipal Council of Batangas enacted Municipal Ordinance No. 7, series of 1924, which imposed taxes on garages. Following the ordinance's implementation, Batangas Transportation Co. was required to pay a garage tax of P405, which it did under protest. Subsequently, the company filed a lawsuit seeking the return of the amount paid, arguing that the ordinance was null and illegal.
During the proceedings, the parties submitted a stipulation of facts, confirming that Batangas Transportation Co. is a corporate entity engaged in the operation of an auto-truck service for transporting passengers and freight in Batangas. The company operates a garage for its vehicles, which are used exclusively for its transportation busi...
Case Digest (G.R. No. 28863)
Facts:
Parties Involved:
- Plaintiff and Appellee: Batangas Transportation Co., a corporation engaged in the operation of an auto-truck service for transporting passengers and freight in Batangas.
- Defendants and Appellants: Provincial Treasurer of Batangas, Municipal Council of Batangas, and Municipal Treasurer of Batangas.
Ordinance in Question:
- The Municipal Council of Batangas passed Ordinance No. 7, Series of 1924, imposing taxes on garages. The plaintiff was classified as a second-class garage and was required to pay a tax of P393.75 plus a penalty of P11.25, totaling P405.
Payment Under Protest:
- The plaintiff paid the tax under protest and later filed an action seeking the return of the sum paid, arguing that the ordinance was null and illegal.
Stipulation of Facts:
- The parties submitted a stipulation of facts, which included details about the plaintiff's business, the nature of its garage, and the operation of its motor vehicles. The plaintiff operates as a common carrier, with motor vehicles used for transporting passengers and freight along routes approved by the Public Service Commission. The garage is used to house, inspect, clean, and repair the vehicles when not in use.
Trial Court Decision:
- The trial court declared the ordinance null and void, ordered the return of the P405 to the plaintiff, and prohibited the enforcement of the ordinance.
Issue:
Validity of the Ordinance:
- Whether Municipal Ordinance No. 7, Series of 1924, is valid and within the authority of the Municipal Council of Batangas to enact.
Applicability of the Tax:
- Whether the plaintiff's garage, used for housing and maintaining its own motor vehicles as a common carrier, falls under the definition of a "garage" subject to taxation under the ordinance.
Authority of the Municipal Council:
- Whether the Municipal Council of Batangas had the authority under Section 2307 of the Administrative Code to impose a tax on the plaintiff's garage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court held that the Municipal Council of Batangas exceeded its authority in enacting Ordinance No. 7, Series of 1924, and that the plaintiff's garage, used for its own motor vehicles as a common carrier, is not subject to the tax imposed by the ordinance. The judgment of the trial court was affirmed, and the defendants were ordered to return the tax collected and refrain from enforcing the ordinance.