Case Digest (G.R. No. 230170) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Mactan–Cebu International Airport Authority (MCIAA) was created on July 31, 1990 by Republic Act No. 6958 to operate and manage the Mactan International Airport and Lahug Airport in Cebu, with a tax‐exempt status under Section 14 of its charter. Respondent City of Lapu‐Lapu, through City Treasurer Elena T. Pacaldo, assessed MCIAA in January 1997 for unpaid real property taxes amounting to over ₱162 million, later reduced to ₱151 million after correcting various discrepancies. MCIAA paid monthly installments until December 2003, totaling over ₱275 million, while disputing the inclusion of airfield, runway, taxiway, and related lots. A 1998 DOJ Opinion confirmed that those properties are owned by the State and merely held in trust. Despite Department of Finance indorsements acknowledging their exempt character, Lapu‐Lapu City issued notices of levy, and in December 2003 auctioned 27 of MCIAA’s properties, which went unsold and were forfeited to the City. MCIAA sought a Case Digest (G.R. No. 230170) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Charter of MCIAA
- Republic Act No. 6958 (July 31, 1990):
- Establishes Mactan–Cebu International Airport Authority (MCIAA) as a body corporate attached to the Department of Transportation and Communications.
- Functions: control, manage, supervise Mactan International Airport (Lapu-Lapu City) and Lahug Airport (Cebu City); develop other Cebu airports.
- Powers: formulate policies; construct, maintain, operate facilities; exercise corporate powers under the Corporation Code; acquire, lease or dispose of properties (except those important to national security without President’s approval); exercise eminent domain; police authority on premises; levy fees.
- Section 14: exempts MCIAA from realty taxes imposed by national or local governments, except for subsidiaries.
- Local Government Code Impact and Tax Assessments
- Mactan–Cebu Intl. Airport Authority v. Marcos (1996): held that RA 7160 (Local Government Code of 1991) withdrew MCIAA’s exemption from real property taxes.
- January 1997: City of Lapu-Lapu issues realty tax assessment (~₱162 million; later adjusted to ₱151 million) covering all airport lots, including airfield/runway/taxiway.
- MCIAA pays installments (₱4 million, then ₱6 million monthly), totaling ₱275.7 million by December 2003, but protests inclusion of exclusively governmental-use lots.
- Administrative Opinions and Local Government Actions
- DOJ Opinion No. 50 (1998): affirms airfield/runway/taxiway are owned by the Republic, held in trust by MCIAA, thus public dominion and tax-exempt.
- Department of Finance indorsements direct City of Lapu-Lapu to transfer these lots to exempt roll (May & Aug 1998).
- City Treasurer issues updated statements (up to 2002) and Notices of Levy on 18 property sets.
- Judicial Proceedings
- RTC Lapu-Lapu City (SCA No. 6056-L, 2003–2005):
- MCIAA files petition for prohibition and TRO/injunction to stop levy/auction; initial TRO granted, later lifted.
- December 2004: preliminary injunction issued; December 2005: lifted upon City’s showing of valid omnibus tax ordinance (Ordinance No. 44, 1980) and authority to collect Special Education Fund (RA 5447) and penalty interest.
- Court of Appeals (CA-G.R. SP 01360, 2007–2008):
- October 8, 2007 Decision: affirms MCIAA as GOCC, not exempt from realty taxes, SEF levy, penalty interest; invalidates auction sale but recognizes City’s limited lien.
- February 12, 2008 Resolution: denies MCIAA’s partial motion for reconsideration (MCIAA vs. MIAA distinction).
- Supreme Court certiorari petition by MCIAA under Rule 45.
Issues:
- Classification of MCIAA: GOCC vs. national government instrumentality.
- Whether MCIAA’s airport lands and buildings (airfield, runway, taxiway, terminal, associated lots) are exempt from local real property taxes.
- Whether City of Lapu-Lapu validly imposed basic real property tax without a new local ordinance.
- Validity of additional 1% Special Education Fund levy without ordinance.
- Validity and extent of penalty interest or surcharge imposed without ordinance.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)