Case Digest (G.R. No. L-1940-42) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lung Center of the Philippines v. Quezon City, decided on June 29, 2004, the Lung Center of the Philippines (LCP), a non-stock, non-profit entity created by Presidential Decree No. 1823 on January 16, 1981, owns a 121,463 sq. m. parcel (Lot No. RP-3-B-3A-1-B-1, TCT No. 261320) at Quezon Avenue corner Elliptical Road, Quezon City, on which it erected a tertiary hospital. LCP renders medical services to paying and charity patients, receives government subsidies and leases ground-floor space and a portion of its land to private parties, including the Elliptical Orchids and Garden Center. On June 7, 1993, the City Assessor assessed LCP’s land and building for real property tax amounting to ₱4,554,860, issuing Tax Declarations Nos. C-021-01226 and C-021-01231. LCP’s Claim for Exemption, based on Section 28(3), Article VI of the 1987 Constitution, was denied by the City Assessor and subsequently dismissed by the Quezon City Local Board of Assessment Appeals (QC-LBAA) and the Centra Case Digest (G.R. No. L-1940-42) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Background
- Petitioner Lung Center of the Philippines (LCP) is a non-stock, non-profit corporation created by Presidential Decree No. 1823 on January 16, 1981.
- It is administered under the Office of the President in coordination with the Ministry of Health and the Ministry of Human Settlements.
- Property Description and Use
- LCP owns Lot No. RP-3-B-3A-1-B-1, SWO-04-000495 (121,463 sqm), TCT No. 261320, at Quezon Avenue corner Elliptical Road, Quezon City. A hospital building stands on the lot.
- Uses of the land/building:
- Ground floor leased to canteen operators, small stores, and private medical practitioners.
- Left side of building: vacant; right corner leased to “Elliptical Orchids and Garden Center.”
- Hospital admits paying and non-paying (charity) patients; renders in-patient/out-patient services; receives annual government subsidies.
- Assessment and Administrative Proceedings
- On June 7, 1993, the City Assessor assessed land and building for real property tax amounting to ₱4,554,860, issuing Tax Declarations Nos. C-021-01226 and C-021-01231.
- On August 25, 1993, LCP filed a Claim for Exemption under its charitable status; the City Assessor denied the claim.
- Appeals:
- QC Local Board of Assessment Appeals (QC-LBAA) dismissed LCP’s petition.
- Central Board of Assessment Appeals (CBAA) affirmed QC-LBAA.
- Court of Appeals in CA-G.R. SP No. 57014 affirmed CBAA on July 17, 2000.
- LCP filed a petition for review on certiorari with the Supreme Court.
Issues:
- Whether the petitioner is a charitable institution under Presidential Decree No. 1823, the 1973 and 1987 Constitutions, and Section 234(b) of Republic Act No. 7160.
- Whether the petitioner’s real properties are exempt from real property taxation under the foregoing laws.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)