Case Digest (G.R. No. 192300) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation v. Municipal Government of Navotas, the petitioner, National Power Corporation (NPC), a government-owned and controlled corporation organized under Republic Act No. 6395, entered into Build-Operate-and-Transfer (BOT) agreements on November 16, 1988, and June 29, 1992, with Mirant Navotas I Corporation and Mirant Navotas II Corporation (formerly Hopewell entities) for the construction, operation, and eventual transfer of 200-MW and 100-MW gas turbine power stations, respectively, in Navotas. Under the BOTs, NPC maintained actual and direct control and bore the obligation to pay all taxes except business taxes. NPC paid real property taxes for the first quarter of 2003 but then ceased payments, asserting exemption per Section 234(c) of the Local Government Code (LGC). On March 30 and July 26, 2004, NPC formally notified the Municipal Assessor of Navotas of its exemption claim regarding machineries and equipment. Despite these notices, the Municipal Tr Case Digest (G.R. No. 192300) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner National Power Corporation (NPC) is a government-owned and controlled corporation organized under RA No. 6395, with principal office in Quezon City.
- Respondents: Municipal Government of Navotas (LGU hosting Navotas Power Stations I & II), Sangguniang Bayan of Navotas (municipal legislative body), and Manuel T. Enriquez (Municipal Treasurer).
- BOT Agreements and Tax Exemption Claim
- NPC entered into Build-Operate-Transfer (BOT) agreements on November 16, 1988 (MNC-I, 200 MW) and June 29, 1992 (MNC-II, 100 MW). Petitioner had operational control and obligation to pay all taxes except business taxes.
- NPC paid real property taxes (RPT) for Q1 2003 (P3.38 M for MNC-I; P4.97 M for MNC-II), then ceased payment, claiming exemption under LGC § 234(c) for machinery and equipment of GOCCs in power generation; notified Municipal Assessor.
- Notices of Delinquency and Legal Proceedings
- On May 25, 2005, Municipal Treasurer issued notices of delinquency for Q2–Q4 2003 and years 2004–2005 (total P148.3 M), followed by a Warrant of Levy and Notices of Sale; properties were auctioned December 21, 2005 and forfeited due to lack of bidders.
- NPC filed a Petition for Declaratory Relief in the RTC of Malabon (December 16, 2005) to annul notices, levy, and sale, and sought a TRO (denied); RTC denied petition May 23, 2007 for failure to exhaust administrative remedies (appeal to LBAA/CBAA). NPC appealed to the Supreme Court.
Issues:
- Does the Court of Tax Appeals (CTA) have jurisdiction under RA 9282 to review RTC decisions in local tax cases involving real property taxes?
- Are appeals to the Local Board of Assessment Appeals (LBAA) and Central Board of Assessment Appeals (CBAA), and payment under protest, required when the legality of a real property tax assessment is challenged?
- Are petitioner’s machineries and equipment exempt from real property tax under LGC § 234(c)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)