Case Digest (G.R. No. 127139) Core Legal Reasoning Model
Facts:
In G.R. No. 127139, decided on February 19, 1999 under the 1987 Constitution, petitioner Jaime C. Lopez assailed the October 24, 1996 Order of the Regional Trial Court of Manila, Branch 39, presided by Hon. Benjamin A.G. Vega, dismissing Civil Case No. 96-77510. Lopez sought a declaration of nullity of City of Manila Ordinance No. 7894, which revised the schedule of fair market values and led to a 580% tax increase on his land and a 250% increase on his improvements, effective January 1, 1996. Ordinance No. 7894 was enacted after the City Assessor, Lourdes Laderas, complied with Section 219 of the Local Government Code (R.A. 7160), preparing updated valuations (initially a 1,700% average increase, later reduced to 1,020%) and submitting them to the City Council. Public hearings and the three readings occurred between September and December 1995, followed by publication in Manila Standard and Balita. Upon implementation, Lopez filed on March 18, 1996 for nullity, injunctive reli
Case Digest (G.R. No. 127139) Expanded Legal Reasoning Model
Facts:
- Legislative requirement and preliminary actions
- Section 219, Republic Act No. 7160 (Local Government Code) required local assessors to undertake a general revision of real property assessments within two years after January 1, 1992 and every three years thereafter.
- In 1992 the City of Manila assessor prepared a schedule of updated values but the City Council took no action; property valuations continued to be based on 1979 market values until 1995.
- Conduct of general revision and enactment of Ordinance No. 7894
- In March 1995 City Assessor Lourdes Laderas initiated the general revision upon receipt of a Department of Finance memorandum; she updated fair market values (initially +600%–3 330%, averaged to +1 700%, then reduced to +1 020%).
- The proposed schedule was submitted to the City Council; public hearings were held (Sept. 28, Oct. 5/12/19, Nov. 27/29), three readings occurred (Sept. 12, Oct. 28, Dec. 12); the ordinance with its schedule was published (Manila Standard Oct. 28; Balita Nov. 1); it was approved Dec. 27, 1995 and took effect Jan. 1, 1996.
- Notice of assessment, petition for nullity, and judicial proceedings
- Notices of revised assessments issued under Section 223, RA 7160 led to Lopez’s tax increase of 580% on land and 250% on improvements; he filed a petition for nullity with TRO and preliminary injunction on March 18, 1996 in RTC–Manila, Branch 5.
- A TRO issued April 10, 1996; on that day Ordinance No. 7905 took effect retroactive to Jan. 1, 1996, halving assessment levels. The trial judge inhibited herself; the case was re-raffled to Branch 39, which on May 9 granted the injunction and denied the City’s motion to dismiss.
- Motion for reconsideration and dismissal
- Respondents moved for reconsideration (May 22, 1996), arguing non-exhaustion of administrative remedies and that Ordinance No. 7905 mooted the petition.
- On October 24, 1996 Branch 39 granted the motion to dismiss for failure to exhaust administrative remedies and mootness; preliminary injunction dissolved. A motion for reconsideration was denied.
Issues:
- Whether the trial court erred in dismissing the petition for failure to exhaust administrative remedies.
- Whether the trial court misapplied Sections 212 and 221 of the Local Government Code regarding the preparation, publication, and effectivity of revised assessments.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)