Case Digest (G.R. No. 215955) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 215955, decided on January 13, 2021, the Metropolitan Waterworks and Sewerage System (MWSS) petitioned for review on certiorari under Rule 45 against the Central Board of Assessment Appeals, the Pasay City Local Board of Assessment Appeals, and the Pasay City Treasurer and City Assessor. MWSS was created by Republic Act No. 6234 on June 19, 1971, as a government instrumentality vested with corporate powers to oversee waterworks and sewerage systems in Metro Manila, Rizal, and parts of Cavite. In 1997, MWSS entered into a concession agreement with Maynilad Water Services, Inc., for the West Zone including Pasay City. On February 21, 2008, the Pasay City Treasurer issued real property tax computations for the 2008 taxable year, assessing MWSS at ₱166,629.36. MWSS protested on February 3, 2008, asserting its exemption as a public utility and government instrumentality under Sections 133(o) and 234(a) of the Local Government Code (LGC), citing Manila International Airpor Case Digest (G.R. No. 215955) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Charter of MWSS
- Republic Act No. 6234 (1971) created the Metropolitan Waterworks and Sewerage System (MWSS) as a government instrumentality vested with corporate powers to ensure water supply and manage sewerage systems in Metro Manila, Rizal, and part of Cavite.
- The Charter exempted MWSS properties and facilities from taxation.
- Concession Agreement
- Under RA No. 8041 (1995), MWSS in 1997 granted a concession to Maynilad Water Services, Inc. for the West Zone (including Pasay City).
- Pasay City asserted that the concession transferred the actual use of MWSS real properties to a taxable entity.
- Tax Assessments and Administrative Proceedings
- In February 2008, the Pasay City Treasurer issued real property tax computations for MWSS (taxable year 2008) amounting to ₱166,629.36; MWSS filed a written protest and later appealed to the Local Board of Assessment Appeals (LBAA).
- The LBAA held MWSS a government-owned or ‑controlled corporation (GOCC), not an instrumentality, and sustained the assessment.
- On appeal, the Central Board of Assessment Appeals (CBAA) affirmed the assessment’s finality on procedural grounds and denied MWSS’s motion for reconsideration, ruling that RPT exemption under MWSS’s Charter was withdrawn by LGC Section 234.
- The Court of Appeals (CA) dismissed MWSS’s appeal for failure to exhaust remedies under LGC Sections 206 and 252; MWSS’s motion for reconsideration was denied (June 3 and December 11, 2014).
- Petition for Review
- MWSS filed a Petition for Review on Certiorari under Rule 45 challenging the CA resolutions.
- The Supreme Court granted partial relief in a decision penned by Justice Lopez on January 13, 2021.
Issues:
- Did the CA err in dismissing MWSS’s appeal for failure to exhaust administrative remedies?
- Is Pasay City authorized to assess and collect real property taxes from MWSS?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)