Case Digest (G.R. No. L-43339)
Facts:
Cagayan Robina Sugar Milling Co. v. Court of Appeals, Central Board of Assessment Appeals, Board of Assessment Appeals, and the Provincial Assessor of Cagayan, G.R. No. 122451, October 12, 2000, the Supreme Court Second Division, Quisumbing, J., writing for the Court.In 1990 the Assets Privatization Trust (APT) offered for sale assets of the foreclosed Cagayan Sugar Corporation (CASUCO) with a floor bid of P355,000,000.00; Cagayan Robina Sugar Milling Co. (petitioner) was the highest bidder and acquired the properties for P464,000,000.00. Among the purchased properties were sugar‑mill machineries located at the CASUCO millsite in Sto. Domingo, Piat, Cagayan.
On October 18, 1990 the Provincial Assessor of Cagayan issued a Notice of Assessment covering the machineries (Tax Declaration No. 5355), fixing market value at P391,623,520.00 and assessed value at P313,298,820.00. Petitioner appealed that assessment to the Local Board of Assessment Appeals (LBAA) on February 8, 1991, and on September 10, 1991 asked the Provincial Assessor to reconsider, arguing that the APT selling price should not be the sole basis because of operating condition, goodwill and future business potential.
On April 1, 1992 the LBAA ruled that the market value for assessment should be the APT floor bid price of P355,000,000.00, deducted land and building values and non‑taxable machineries to arrive at a market value for taxable machineries of P260,327,060.00 and an assessed value of P208,261,650.00 (Declaration No. 5514). Although petitioner prepared an “Appeal of Assessment” dated April 18, 1992, it did not file with the Central Board of Assessment Appeals (CBAA) until November 25, 1992.
The LBAA and Provincial Assessor moved on January 2, 1994 to dismiss the November 25, 1992 appeal as filed beyond the thirty‑day reglementary period. On May 17, 1994 the CBAA dismissed petitioner’s appeal as time‑barred; a motion for reconsideration was denied by resolution dated June 30, 1994. Petitioner then filed a special civil action for certiorari in this Court (docketed G.R. No. 116795) on October 3, 1994, challenging the CBAA decisions for grave abuse of discretion; pursuant to Revised Administrative Circular No. 1‑95 the petition was referred to the Court of Appeals.
The Court of Appeals in CA‑G.R. SP No. 37934 denied the p...(Subscriber-Only)
Issues:
- Was petitioner’s appeal to the Central Board of Assessment Appeals time‑barred under the Real Property Tax Code (procedural issue)?
- Was the assessment of petitioner’s machineries, and the market‑value methodology used by the LBAA and affirmed by the CBAA and Court of Appeals, proper under the Real Property Tax C...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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