Case Digest (G.R. No. L-50466)
Facts:
In Caltex (Philippines) Inc. v. Central Board of Assessment Appeals and City Assessor of Pasay (G.R. No. 50466, May 31, 1982), Caltex, owner of gas station machinery and equipment installed on leased lots in Pasay City, contested realty tax assessments imposed by the City Assessor. The items included underground gasoline tanks, elevated water tanks, pumps, hoists, compressors, neon signboards, concrete fences, pavement and related fixtures. Caltex leased these machines to station operators under contracts requiring their return in good condition, retaining ownership throughout the lease. The City Assessor characterized all equipment as real property subject to annual ad valorem tax, amounting to ₱4,541.10. The City Board of Tax Appeals initially ruled them personalty, but the Central Board, chaired by the Secretary of Finance, reversed that decision on June 3, 1977, holding the items taxable as machinery and improvements under Presidential Decree NoCase Digest (G.R. No. L-50466)
Facts:
- Parties
- Petitioner: Caltex (Philippines) Inc. (“Caltex”)
- Respondents: Central Board of Assessment Appeals and City Assessor of Pasay City
- Subject Matter
- Machinery and equipment installed by Caltex in its gas stations on leased land, consisting of:
- Underground gasoline tanks and steel piping
- Elevated water tanks, gasoline pumps, computing pumps, water pumps
- Car washer, car hoists, truck hoists, air compressors, tire inflators
- Neon light signboards, concrete fence, pavement, and the gas station sheds/buildings
- Lease Agreements
- Caltex owns the equipment and loans them to station operators
- Operators must return equipment in good condition; lessor of land never acquires ownership
- Procedural History
- Pasay City Assessor: characterized the equipment as taxable realty; assessed annual realty tax of ₱4,541.10
- City Board of Tax Appeals: ruled the items as personalty
- Central Board of Assessment Appeals: reversed, holding the items are “real property” under Sections 3(k), 3(m), and 38 of the Real Property Tax Code (P.D. No. 464)
- Caltex’s Remedy: filed petition for certiorari in the Supreme Court to set aside Board’s decision and declare the equipment as personal property
Issues:
- Jurisdictional Issue
- Whether the Supreme Court may entertain a certiorari petition to review the decision of the Central Board of Assessment Appeals
- Substantive Issue
- Whether the machinery and equipment installed in Caltex’s gas stations are subject to real property tax under the Assessment Law and the Real Property Tax Code
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)