G.R. No. 184203 - City of Lapu-Lapu vs. Philippine Economic Zone Authority

Presidential Decree No. 66 (1972) created the Export Processing Zone Authority (EPZA) as a non-profit entity and declared it exempt from all taxes, including real property taxes (RPT).
Republic Act No. 7916 (1995) established the Philippine Economic Zone Authority (PEZA) to operate, administer and develop economic zones, directing by Executive Order No. 282 that PEZA assume EPZA’s powers and tax-exempt status.
Two local government units demanded RPT from PEZA:

City of Lapu-Lapu assessed PEZA’s Mactan zone properties for 1992–2002 (up to ₱86.8 M).
Province of Bataan billed PEZA’s Mariveles zone properties for 1995–2004 (up to ₱110.5 M).

In 1998–2002 the City issued demands and final assessments; PEZA filed a declaratory relief petition in RTC Pasay (Br. 111) to declare itself tax-exempt.
RTC granted relief (citing LGC Secs. 24, 51); City appealed to the CA, which dismissed the appeal for raising pure questions of law under Rule 50.
City elevated to the Supreme Court, challenging CA’s procedural ruling, RTC’s venue/jurisdiction, and non-joinder of other LGUs.

Province of Bataan served tax bills (2003–2004) and threatened public auction; PEZA filed a petition for injunction in RTC Pasay (Br. 115).
RTC denied relief (holding PEZA taxable under LGC); PEZA sought certiorari in CA, which granted relief and nullified all tax collection proceedings.
Province moved for reconsideration; Supreme Court consolidated both petitions for review on certiorari.

Did the Court of Appeals err in dismissing City of Lapu-Lapu’s appeal for raising pure questions of law?
Did RTC Pasay Branch 111 have jurisdiction over PEZA’s petition for declaratory relief?
Was PEZA’s injunctive petition in RTC Pasay a local tax case appealable only to the Court of Tax Appeals?
Is PEZA exempt from payment of real property taxes?