Case Digest (G.R. No. 261472) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Food Authority (NFA), represented by Atty. Ma. Theresa S. Villafuerte as petitioner, versus the City Government of Tagum, through its City Assessor and City Treasurer, respondents, the Supreme Court, En Banc, resolved G.R. No. 261472 on May 21, 2024 under the 1987 Constitution. NFA owns lands, buildings, and machinery in Barangay Magdum, Tagum City, Davao del Norte, covered by Transfer Certificates of Title Nos. T-59639, T-59640 and seven tax declarations. After Republic Act No. 7160 (1991 LGC) withdrew prior tax exemptions, Tagum City demanded real property taxes totaling ₱2,643,816.53 via seven Notices of Delinquency dated August 2, 2016. NFA sought exemption: it relied on the MIAA v. Court of Appeals test for government instrumentalities, two OGCC opinions (May 29 and October 24, 2007), and its charter under PD 4, PD 1485, PD 1770 and RA 11203. The Regional Trial Court of Tagum City, Branch 31, dismissed NFA’s Petition for Prohibition on November 15, 2016; its mot Case Digest (G.R. No. 261472) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Background
- Petitioner: National Food Authority (NFA), represented by Atty. Ma. Theresa S. Villafuerte, CPA
- Respondents: City Government of Tagum, City Assessor, City Treasurer of Tagum, Davao del Norte
- Case Trajectory:
- 2016 – RTC Tagum City: Petition for Prohibition filed
- 2017–2018 – CTA Second Division: Petition for Review and Motion for Suspension resolved
- 2020 – CTA En Banc Decision dismissing petition; 2021 – Resolution denying reconsideration
- 2024 – Petition for Review on Certiorari under Rule 45 to SC
- Evolution and Nature of NFA
- Historical Development of Rice/Corn Agencies:
- 1936–1947: NARIC under NDC; 1950–51: transfer to PRISCO; 1951: RA 663 reconstituted NARIC; 1962: RCA via RA 3452; 1964: RICOB via EO 62; 1972: NGA via PD 4
- 1975–1981: Expansion of NGA (PD 669, PD 1485); 1981: reconstituted as NFA (PD 1770); various EO transfers between OP and DA; 2019: RA 11203 refocused NFA on rice buffer stock
- Charter and Functions under PD 1770 & RA 11203:
- Promote integrated development of grains industry; stabilize supply/prices; maintain rice buffer stock sourced from local farmers for calamity relief
- Corporate powers: contract, import/export, supervise, own/dispose property; funded/capitalized by National Government; sovereign guarantee
- Tax Dispute Facts
- NFA Properties in Tagum City: TCT Nos. T-59639, T-59640; Tax Declarations Nos. 01-0010-03091 to 03096, 00732
- LGC 1991 Sec. 234 withdrew prior RPT exemptions for GOCCs—NFA initially paid taxes post-1991
- OGCC Opinions 098 & 228 (2007): NFA deemed government instrumentality; NFA ceased RPT payments (June/Nov 2007)
- August 2, 2016: Notices of Delinquency issued for PHP 2,643,816.53
- Proceedings: RTC Tagum City (Petition for Prohibition), CTA Second Division (Petition for Review, SOTC), CTA En Banc (Certiorari Decision/Resolution), SC (Rule 45 Petition)
Issues:
- Jurisdiction and Procedural Prerequisites
- Does RTC Tagum City have jurisdiction over NFA’s Petition for Prohibition?
- Is “payment under protest” under LGC Sec. 252 an absolute prerequisite before judicial challenge of RPT?
- Classification and Tax Exemption
- Is NFA a “government instrumentality vested with corporate powers” or a GOCC?
- Is NFA exempt from real property tax under LGC Secs. 133(o) and 234(a)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)