Philippine Heart Center vs. Local Government of Quezon City

Facts:

The petitioner, Philippine Heart Center (PHC), is a specialty hospital created by Presidential Decree (PD) No. 673 (1975) and later covered by Letter of Instruction (LOI) 1455 (1985) extending tax exemption; respondents are the Local Government of Quezon City, its City Mayor, City Treasurer and City Assessor. PD 673 vested the PHC with corporate powers to acquire and dispose of property and directed initial government support; it also envisioned PHC’s public-welfare objective of delivering cardiovascular care to the poor.

In 2004 the Quezon City government issued final notices of delinquency for alleged unpaid real property taxes totaling Php36,530,545.00 on eleven PHC properties in Quezon City; the City Treasurer subsequently levied on the properties, issued a warrant of levy (June 13, 2011), and after public auction on July 7, 2011 the City purchased the properties as sole bidder. PHC sought executive relief (a letter to the President) and entered into Memoranda of Agreement with Quezon City (2006 and 2010) to provide free services in lieu of taxes, but implementation was suspended after an OGCC memorandum (Aug. 22, 2006) citing the Court’s ruling in Manila International Airport Authority v. Court of Appeals (MIAA) and the PHC’s claimed tax-exempt status.

PHC filed a petition for certiorari in the Court of Appeals (CA) on September 1, 2011 alleging grave abuse of discretion in assessment, levy and sale. The CA initially dismissed the petition (Sept. 25, 2012) for failure to exhaust administrative remedies under Section 252 of RA 7160 (Local Government Code), but on motion reinstated the petition (Resolution, Mar. 18, 2013) finding administrative remedies inadequate because the properties had already been sold. The CA later dismissed the petition again (Decision, Mar. 15, 2016), holding certiorari was the wrong remedy because the acts challenged were not judicial or quasi‑judicial; its denial of reconsideration followed (Resolution, June 23, 2016).

PHC brought the present petition for review on certiorari to the Supreme Court assailing the CA’s March 15, 2016 Decision and June 23, 2016 Resolution. The PHC contended it was exempt from local real property taxes under PD 673 and LOI 1455 and alternatively as a charitable institution under Article III, Section 28(3) of the 1987 Constitution and Section 234(b) of RA 7160;...(Pro-only)

Issues:

• Did the PHC comply with the Rules of Court on verification and certification against forum shopping?
• Was a petition for certiorari the proper remedy to challenge respondents’ assessment, levy, and sale of the PHC’s properties?
• Is the PHC exempt from paying real property taxes on the eleven properties and were the assess...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)