Case Digest (A.C. No. 2474)
Facts:
In Manila International Airport Authority v. City of Pasay (G.R. No. 163072, April 02, 2009), the Manila International Airport Authority (MIAA), created under Executive Order No. 903 (21 July 1983) to operate the Ninoy Aquino International Airport (NAIA) Complex, was assessed by the City of Pasay for alleged real property tax delinquencies covering 1992–2001 on approximately 600 hectares of airport land, runways, terminals, and related improvements located in Pasay City. On 28 August 2001, MIAA received final notices of real property tax delinquency and, shortly thereafter, warrants of levy for ten tax declarations, totaling over P1 billion, and was threatened with public auction by the City Mayor of Pasay. On 29 October 2001, MIAA filed with the Court of Appeals a petition for prohibition and injunction, praying for a preliminary injunction or temporary restraining order to enjoin the City from imposing realty taxes, levying upon, or auctioning the NAIA Pasay properties. The Co...Case Digest (A.C. No. 2474)
Facts:
- Establishment and Operation of MIAA
- Executive Order No. 903 (21 July 1983) created the Manila International Airport Authority (MIAA) and transferred some 600 hectares—including runways, tower and other airport buildings—to MIAA.
- MIAA is tasked to administer and operate the Ninoy Aquino International Airport (NAIA) Complex situated along the Pasay–Parañaque City border.
- Real Property Tax Assessments and Proceedings
- On 24 August 2001, the City Treasurer of Pasay issued Final Notices of Real Property Tax Delinquency for taxable years 1992–2001, totaling ₱1,016,213,836.33 (tax due and penalties).
- Notices of levy and warrants of levy were issued and received by MIAA on 28 August 2001; the City Mayor threatened public auction of the NAIA Pasay properties.
- On 29 October 2001, MIAA filed with the Court of Appeals a petition for prohibition and injunction (with prayer for TRO/preliminary injunction) to enjoin assessment, levy and auction of the NAIA Pasay properties.
- The Court of Appeals dismissed the petition via Decision (30 October 2002) and denied reconsideration (19 March 2004). MIAA filed this petition for review on certiorari under Rule 45.
Issues:
- Whether the NAIA Pasay properties of MIAA are exempt from real property tax under the Local Government Code.
- Whether MIAA qualifies as a “taxable person” under Sections 133(o), 193 and 234 of Republic Act No. 7160 (Local Government Code).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)