Case Digest (G.R. No. 225409) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Heart Center v. Local Government of Quezon City (G.R. No. 225409, February 28, 2022), the Philippine Heart Center (PHC), a specialty hospital created by Presidential Decree No. 673 (PD 673) in 1975 and granted tax exemption under Section 6 of the same decree and Letter of Instruction No. 1455 (1985), owns eleven land and building parcels in Quezon City. In 2004, the Quezon City Government issued Final Notices of Delinquency for unpaid real property taxes amounting to ₱36,530,545 and, upon nonpayment, levied on PHC properties. The PHC entered into Memoranda of Agreement with the city in 2006 and 2010 to settle its alleged liability by providing free services but later suspended performance, invoking the Court’s ruling in Manila International Airport Authority v. Court of Appeals (MIAA) on government tax exemption. The city nevertheless issued a Warrant of Levy in June 2011, sold the properties at public auction on July 7, 2011, and became the sole purchaser. PHC fil Case Digest (G.R. No. 225409) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Dispositions Assailed
- The Court of Appeals, in CA-G.R. SP No. 121019, issued:
- Decision (March 15, 2016) dismissing Philippine Heart Center’s (PHC) petition for certiorari as the wrong remedy against assessment, levy, and sale of its properties.
- Resolution (June 23, 2016) denying PHC’s motion for reconsideration.
- PHC’s petition before the Supreme Court seeks to annul these rulings.
- Antecedents
- Establishment and Charters
- PD 673 (1975) created the PHC as a specialty hospital with a ten-year tax exemption; LOI 1455 (1985) extended the exemption “without interruption.”
- PD 673 authorized PHC to acquire, hold, encumber, lease, sell or dispose of properties and endowed it with corporate powers.
- Properties and Tax Notices
- PHC owned eleven parcels in Quezon City under various tax declarations.
- In 2004, QC issued Final Notices of Delinquency for ₱36,530,545 real property taxes; properties were levied.
- Agreements and Withholding of Payments
- MOA 2006: PHC to render free medical services in lieu of tax payment; suspended after OGCC memorandum (Aug 22, 2006) citing MIAA decision.
- MOA 2010: similar terms; implementation suspended by new PHC director.
- Levy and Sale (2011)
- QC issued new Notices of Delinquency (June 1, 2011) and Warrant of Levy (June 13, 2011).
- Public auction (July 7, 2011): QC Government was lone bidder and purchased the properties.
- CA Proceedings
- PHC filed certiorari petition (Sept 1, 2011) alleging grave abuse of discretion and tax exemption under PD 673, LOI 1455, Constitution, RA 7160, and prior jurisprudence (MIAA, MCIAA).
- Respondents moved to dismiss for failure to exhaust administrative remedies, lack of jurisdiction, improper verification, non-payment of deposit under RA 7160 §267, and insufficient proof of exemption.
- CA initially dismissed for non-exhaustion (Sept 25, 2012), reinstated petition on exceptions (Mar 18, 2013), then dismissed again as wrong remedy (Mar 15, 2016).
Issues:
- Whether PHC substantially complied with verification and certification against forum shopping.
- Whether certiorari is the proper remedy to challenge respondents’ assessment, levy, and sale.
- Whether PHC and its Quezon City properties are exempt from real property taxes and whether the levy and sale are void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)