Case Digest (G.R. No. L-17870) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mindanao Bus Company v. City Assessor & Treasurer and Board of Tax Appeals (G.R. No. L-17870, September 29, 1962), petitioner Mindanao Bus Company, a public utility transporting passengers and cargo throughout Mindanao, maintained its main office and repair shop in Cagayan de Oro City with branch stations in Iligan, Pagadian, Davao and Kibawe. The City Assessor valued at ₱4,400 a group of maintenance and repair machines—among them a Hobart electric welder, Storm boring machine, lathe, grinder, hydraulic press, battery charger and Waukesha engine—each set upon wooden or cement platforms in petitioner’s garage. Contending these items were movable tools and not subject to realty tax, petitioner appealed the assessment to the Board of Tax Appeals, which upheld it. Upon denial of reconsideration, the case proceeded to the Supreme Court by way of a petition for review from the Court of Tax Appeals decision. The parties had stipulated that the machines served only petitioner’s in‐ho Case Digest (G.R. No. L-17870) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Assessment
- Mindanao Bus Company (petitioner), a public utility transporting passengers and cargo in Mindanao, was assessed P4,400 realty tax on its maintenance and repair equipment by the City Assessor of Cagayan de Oro.
- Petitioner appealed to the Board of Tax Appeals (BTA), which sustained the assessment, then to the Court of Tax Appeals (CTA), which likewise upheld it.
- Stipulated Facts
- Petitioner’s main office and garage are in Cagayan de Oro City, with branches in Iligan, Pagadian, Davao, and Kibawe.
- Seven pieces of machinery—Hobart electric welder, Storm boring machine, lathe with motor, Black & Decker grinder, PEMCO hydraulic press, battery charger, and Waukesha engine—sit on cement or wooden platforms in petitioner’s repair shop.
- These machines are used exclusively to service petitioner’s own trucks, never to produce goods for sale or to serve the general public.
- Procedural Posture
- After the CTA denied petitioner’s motion for reconsideration, petitioner filed a petition for review with the Supreme Court.
- Petitioner assigned errors concerning (a) the validity of the assessment, (b) interpretation of Civil Code Art. 415(5), (c) limits under R.A. 521 § 31(c), and (d) denial of reconsideration.
Issues:
- Are the subject machines “immovable property” taxable under Civil Code Article 415(5)?
- Was the CTA’s interpretation of Article 415(5) correct in deeming the equipment realty?
- Does R.A. 521 § 31(c) restrict the City Assessor from levying real estate tax on machinery?
- Did the CTA err in denying petitioner’s motion for reconsideration?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)