Case Digest (G.R. No. 95031) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Mactan Cebu International Airport Authority (MCIAA) was created by Republic Act No. 6958 to manage and develop the Mactan International Airport in Cebu and the Lahug Airport in Cebu City. Section 14 of its Charter expressly exempted it from realty taxes imposed by national or local governments. On October 11, 1994, Eustaquio B. Cesa, Officer-in-Charge of the Cebu City Treasurer’s Office, demanded payment of real property taxes totaling ₱2,229,078.79 on numerous parcels of MCIAA land in Barangays Apas and Kasambagan, Lahug, Cebu City. MCIAA objected, relying on its Charter exemption and Section 133 of the Local Government Code of 1991, which limits local taxing power over instrumentalities of the national government. The City countered that Sections 193 and 234 of the same Code, effective January 1, 1992, withdrew all tax exemptions previously enjoyed by government-owned and controlled corporations (GOCCs), including MCIAA. Facing an imminent warrant of levy, MCIAA pai Case Digest (G.R. No. 95031) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Charter of MCIAA
- Republic Act No. 6958 (RA 6958) establishes the Mactan Cebu International Airport Authority (MCIAA) to manage Mactan International Airport and Lahug Airport, promote air traffic in Central Visayas and Mindanao, and upgrade airport facilities (Sec. 3).
- Section 14 of RA 6958 grants MCIAA exemption from realty taxes imposed by the National Government or any of its political subdivisions.
- Events Leading to the Dispute
- On October 11, 1994, Eustaquio B. Cesa, OIC of the Cebu City Treasurer’s Office, demanded real property tax of ₱2,229,078.79 for several MCIAA-owned parcels in Lahug, Cebu City.
- MCIAA objected, invoking:
- The City of Cebu countered that Sections 193 and 234 of the LGC (effective January 1, 1992) withdrew all tax exemptions previously enjoyed by government-owned or controlled corporations.
- Trial Court Proceedings
- MCIAA filed a Petition for Declaratory Relief (Civil Case No. CEB-16900) on December 29, 1994, and paid the tax “under protest.”
- On March 22, 1995, RTC Branch 20 dismissed the petition, holding that the LGC repealed MCIAA’s charter exemption (citing Sec. 534, RA 7160).
- A motion for reconsideration was denied on May 4, 1995. MCIAA then petitioned the Supreme Court under Rule 45.
Issues:
- Whether MCIAA, as a government-owned corporation performing governmental functions, qualifies as an “agency or instrumentality of the National Government” and is thus immune from local real property tax under LGC Section 133(o).
- Whether Sections 193 and 234 of the LGC validly withdrew MCIAA’s realty tax exemption under RA 6958 and rendered it liable for real property taxes to the City of Cebu.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)