Case Digest (G.R. No. 211299)
Facts:
Light Rail Transit Authority v. City of Pasay, G.R. No. 211299, June 28, 2022, the Supreme Court En Banc, Hernando, J., writing for the Court.From 1985 to 2001 the City of Pasay assessed real property taxes against lands, buildings, machineries, carriageways and passenger terminal stations registered in the name of the Light Rail Transit Authority (LRTA). LRTA initially admitted tax liabilities, sought installment arrangements and condonation of penalties, but ultimately failed to pay; the City issued notices of delinquency and warrants of levy.
LRTA filed a Petition for Certiorari, Prohibition and Mandamus in the Regional Trial Court (RTC) of Pasay, docketed R-PSY-12-09347-CV, challenging the City’s assessments and collection. The RTC (Branch 109) dismissed the Rule 65 petition on January 3, 2013 for being an improper remedy and for LRTA’s alleged failure to exhaust administrative remedies; the RTC denied reconsideration on March 7, 2013.
LRTA appealed to the Court of Appeals (CA) in CA‑G.R. SP No. 129922. On October 8, 2013 the CA affirmed the RTC in toto, holding LRTA had not exhausted administrative remedies and that LRTA remained a taxable entity under this Court’s earlier decision in Light Rail Transit Authority v. Central Board of Assessment Appeals (396 Phil. 860 (2000)). LRTA’s motion for reconsideration before the CA was denied on January 29, 2014.
LRTA then filed a petition under Rule 45 of the Rules of Court with the Supreme Court, seeking to set aside the CA’s October 8, 2013 Decision and January 29, 2014 Resolution. LRTA invoked this Court’s later jurisprudence, particularly Manila International Airport Authority v. Court of Appeals (528 Phil. 181 (2006), “2006 MIAA Case”), and Ty v....(Subscriber-Only)
Issues:
- Was LRTA required to exhaust administrative remedies before filing its Rule 65 petition in the RTC?
- Is LRTA a taxable entity under prior precedent (the 2000 LRTA Case), or should that classification be revisited in light of the 2006 MIAA Case?
- If LRTA is a government instrumentality, are its properties exempt from local real property tax, and are there exceptions (e.g., por...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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