Case Digest (G.R. No. 169836) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Fisheries Development Authority v. Court of Appeals, the petitioner Philippine Fisheries Development Authority (Authority) challenged real property tax assessments imposed by the City of Iloilo on the Iloilo Fishing Port Complex (IFPC). On August 11, 1976, Presidential Decree No. 977 created the Authority under the Ministry of Natural Resources, later amended by Executive Order No. 772 on February 8, 1982, and attached to the Department of Agriculture under Executive Order No. 292. Beginning October 31, 1981, the Ministry of Public Works and Highways reclaimed a 21-hectare parcel in Barangay Tanza, Iloilo City, and constructed the IFPC—comprising breakwater, quay, refrigeration building, market hall, municipal shed, administration building, and utilities—then turned it over to the Authority while title remained with the Republic of the Philippines. The Authority leased portions to private operators. In May 1988, the City assessed the entire IFPC for real property t Case Digest (G.R. No. 169836) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Organization of the Authority
- On August 11, 1976, Presidential Decree No. 977 (PD 977) created the Philippine Fisheries Development Authority (PFDA) under the direct control of the Secretary of Natural Resources.
- On February 8, 1982, Executive Order No. 772 amended PD 977 renaming the agency “Philippine Fisheries Development Authority” and attaching it to the Ministry of Natural Resources; upon effectivity of EO 292 (Admin Code), PFDA became an attached agency of the Department of Agriculture.
- Establishment and Turnover of the Iloilo Fishing Port Complex (IFPC)
- Beginning October 31, 1981, the Ministry of Public Works and Highways reclaimed a 21-hectare parcel in Barangay Tanza, Iloilo City and constructed the IFPC (breakwater, landing quay, refrigeration building, market hall, municipal shed, administration building, utilities, and related facilities).
- Upon completion, MPWH turned over IFPC to PFDA pursuant to Section 11 of PD 977; title to land and buildings remained with the Republic of the Philippines, while PFDA leased portions to private fishing-related firms.
- Tax Assessment and Administrative/Judicial Proceedings
- In May 1988, the City of Iloilo assessed real property taxes on the entire IFPC for fiscal years 1988–1989, resulting in a delinquency of ₱5,057,349.67 (inclusive of penalties and interest); the City scheduled a public auction for August 30, 1990.
- PFDA filed an injunction in the Regional Trial Court; parties agreed to administrative relief. The Iloilo City Assessor denied tax exemption; on March 6, 1992, the Department of Finance ruled PFDA liable for taxes on the beneficial use but clarified only PFDA-owned property could be auctioned.
- PFDA’s petition to the Office of the President was dismissed and motion for reconsideration denied; the Court of Appeals (June 21, 2005) affirmed and held the entire IFPC subject to auction. PFDA filed a petition for review with the Supreme Court.
Issues:
- Is PFDA liable to pay real property taxes to the City of Iloilo on the IFPC?
- If PFDA is liable, may the IFPC be sold at public auction to satisfy the tax delinquency?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)