G.R. No. 193789 - Naranjo vs. Biomedica Health Care, Inc.

On June 26, 1995, petitioner CE Casecnan Water and Energy Company, Inc. and the National Irrigation Administration (NIA) entered into a build-operate-transfer (BOT) contract known as the "Amended and Restated Casecnan Project Agreement" (Casecnan Contract).
The project involved the construction and development of the Casecnan Multi-Purpose Irrigation and Power Project in Pantabangan, Nueva Ecija and Alfonso Castaneda, Nueva Vizcaya, which combined irrigation and hydroelectric power generation utilizing the Pantabangan Dam.

On September 29, 2003, petitioner and NIA executed a Supplemental Agreement amending Article II of the Casecnan Contract.
Under Article 2.2 of the Agreement, NIA was mandated to reimburse petitioner for real property taxes (RPT), provided that such taxes were paid on NIA’s directive and with the concurrence of the Department of Finance.

On September 6, 2005, petitioner received a Notice of Assessment of Real Property from the Office of the Provincial Assessor, covering the years 2002 to 2005, amounting to P248,676,349.60.
Petitioner contested the assessment before the Nueva Ecija Local Board of Assessment Appeals (LBAA), which subsequently dismissed the protest on January 26, 2006.
Petitioner escalated the issue by filing a Notice of Appeal with the Nueva Ecija Central Board of Assessment Appeals (CBAA).
During the pendency of the appeal, respondents collected additional RPT for subsequent years (2006 up to the second quarter of 2008) totaling P363,703,606.88.

Further correspondence indicated alleged arrearages: a letter dated July 9, 2008 reported arrearages of P1,277,474,342.10, and another letter dated August 29, 2008 clarified arrearages at P1,279,997,722.70 (the 2008 RPT Reassessment).
Petitioner, questioning the validity of these tax assessments, filed a Complaint for injunction and damages with the Regional Trial Court (RTC) of San Jose City, Nueva Ecija on September 23, 2008, seeking a temporary restraining order (TRO) and a preliminary injunction to halt the collection of the assessed RPT.
Petitioner maintained that the tax liability should be borne by NIA pursuant to the provisions of the Supplemental Agreement.

On September 24, 2008, the RTC initially denied petitioner’s application for a 72-hour TRO.
Following further demands for payment—including a letter dated September 22, 2008 regarding the third quarter of 2008—the petitioner filed an Amended Complaint on September 29, 2008 to enjoin collection based on the 2008-3Q Assessment amounting to P53,346,755.18.
On October 2, 2008, the RTC issued a 20-day TRO enjoining respondents from collecting the re-assessed RPT (including surcharges and penalties).
The RTC later denied petitioner’s application for a writ of preliminary injunction (October 24, 2008) and also dismissed the Motion for Reconsideration (January 30, 2009).

On April 24, 2009, petitioner filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA) to annul and set aside the RTC’s interlocutory orders.
In its November 2, 2010 decision, the CA ruled that the petition was an offshoot of the 2008 RPT Reassessment. Since the case involved issues concerning the validity of RPT assessments—intrinsically a local tax matter—the CA held that jurisdiction over the case lay exclusively with the Court of Tax Appeals (CTA).
The CA dismissed the petition for lack of jurisdiction and also denied petitioner’s Motion for Reconsideration in a Resolution dated March 24, 2011.

The subject matter of its petition was an ordinary civil action for injunction and not a local tax case.
Its petition did not challenge the assessment per se but sought to enjoin respondents from collecting the assessed RPT during the pendency of administrative proceedings.

The issue of whether to issue a writ of injunction necessarily required determining the propriety of the RPT assessment, categorizing it as a local tax case.
Petitioner failed to exhaust administrative remedies and that matters of local taxation, including RPT, fall under the exclusive appellate jurisdiction of the CTA.

Whether the petition for certiorari, which assailed the RTC’s interlocutory order in a case involving the assessment and collection of real property taxes, falls under the exclusive jurisdiction of the Court of Tax Appeals (CTA).
Whether the nature of the underlying case qualifies as a local tax case, despite being framed as an injunction action.
Whether allowing the CA to decide on the certiorari petition would create a problematic split in jurisdiction over essentially the same subject matter.