Case Digest (G.R. No. 155650) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 155650 decided on July 20, 2006, the Manila International Airport Authority (MIAA), operator of Ninoy Aquino International Airport under Executive Order No. 903 (as amended by EO 909 and EO 298), filed a petition for review under Rule 45 to restrain the City of Parañaque and its officials—the City Mayor, Sangguniang Panglungsod, City Assessor, and City Treasurer—from levying real estate taxes on about 600 hectares of Airport Lands and Buildings. Under Section 21 of its charter, MIAA enjoyed express exemption from real estate tax, but in 1997 the Office of the Government Corporate Counsel (OGCC) opined that the Local Government Code of 1991 withdrew this privilege. MIAA paid some taxes for 1992–1997 but received final delinquency notices for 1992–2001 totaling ₱624,506,725.42. When the local treasury threatened auction on July 17, 2001, and again in early 2003, MIAA secured a temporary restraining order from the Supreme Court, only to find the scheduled auction had al Case Digest (G.R. No. 155650) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Charter of MIAA
- Executive Order No. 903 (21 July 1983) created the Manila International Airport Authority (MIAA) as a separate, autonomous, corporate instrumentality attached to the Ministry (later Department) of Transportation and Communications.
- EO 903 transferred some 600 hectares of airport land, buildings, runways and equipment from the Bureau of Air Transportation to MIAA, subject to presidential approval for any sale or disposition.
- MIAA enjoys corporate powers (e.g., to sue and be sued, adopt bylaws, exercise eminent domain, enter contracts, borrow with presidential consent) and must remit 20% of its gross operating income to the National Treasury.
- Real Estate Tax Controversy
- Originally exempt under Section 21 of its charter, OGCC Opinion No. 061 (1997) held that the Local Government Code (LGC) withdrew MIAA’s tax exemption, prompting MIAA to negotiate tax payments with Parañaque City and pay some amounts due.
- In 2001 the City issued final notices of real estate tax delinquency (1992–2001) totaling over ₱624 million (tax plus penalties). The City then issued warrants of levy and threatened auction sale.
- MIAA filed a petition in the Court of Appeals (CA-G.R. SP No. 66878) on 1 October 2001 seeking prohibition and injunction against the tax imposition, levy and sale. The CA dismissed it as filed beyond the 60-day reglementary period and denied reconsideration.
- MIAA filed before the Supreme Court on 5 December 2002 a petition for review under Rule 45. Meanwhile, Parañaque City published auction notices for 7 February 2003.
- On 6 February 2003 MIAA filed an urgent ex-parte motion for TRO, which the Supreme Court granted on 7 February 2003—but received by the City only after the scheduled sale had concluded. The TRO was confirmed nunc pro tunc on 10 February 2003.
Issues:
- Tax Exemption
- Whether the Airport Lands and Buildings of MIAA are exempt from local real estate tax under existing laws (charter, Civil Code, LGC)?
- Effect of Exemption
- If exempt, whether the assessments, delinquencies, and auction proceedings are void?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)