G.R. No. 127383 - City of Davao vs. Regional Trial Court

On April 8, 1994, the GSIS Davao City branch received a Notice of Public Auction for three GSIS-owned parcels in Matina and Ulas, Davao City, due to non-payment of real property taxes for 1992–1994 amounting to ₱295,721.61.
The auction was reset following a deadline extension by Davao City. On July 28, 1994, GSIS received Warrants and Notices of Levy; another auction notice set the sale on September 20, 1994.

On September 13, 1994, GSIS filed a Petition for Certiorari, Prohibition, Mandamus, and/or Declaratory Relief (with TRO) before RTC Branch 12, challenging the levies and auction.
The RTC issued a 20-day temporary restraining order (TRO) on September 13, 1994, and on April 3, 1995, granted a writ of preliminary injunction for the suit’s duration.
Parties stipulated that the sole issue was whether Sections 193 and 294 (withdrawal of GOCC tax exemptions) and related LGC provisions repealed GSIS’s tax exemption under Section 33 of P.D. No. 1146, as amended by P.D. No. 1981.

On May 28, 1996, the RTC held that GSIS’s tax exemption survived the LGC, voided the warrants of levy, and enjoined further auction and title annotations.
GSIS’s Motion for Reconsideration was denied on October 30, 1996. Petitioners elevated the case to the Supreme Court on pure questions of law.

Did the Local Government Code (R.A. No. 7160), particularly Sections 193, 232, 234, and 534(f), effectively withdraw GSIS’s real property tax exemption granted under Section 33 of P.D. No. 1146, as amended by P.D. No. 1981?
Are the conditionalities in the second paragraph of Section 33, P.D. No. 1146 (requiring an express repeal and a substitute policy for solvency), valid constraints on the legislative power of future Congresses?