Case Digest (G.R. No. 190324)
Facts:
The PHILIPPINE PORTS AUTHORITY, petitioner, received a real property tax assessment from the City Assessor of Davao on June 17, 2004 for properties at Sasa Port and appealed to the Local Board of Assessment Appeals on August 2, 2004; the LBAA dismissed the appeal on January 25, 2005 and the Central Board of Assessment Appeals (CBAA) denied reconsideration on April 7, 2005. The petitioner appealed to the Court of Tax Appeals, which, in a July 30, 2007 Decision made final and executory on February 13, 2008, declared the Sasa Port and its buildings exempt and set aside the assessments, while the City proceeded to advertise and sell the disputed properties; the petitioner filed a petition for certiorari with the Court of Appeals, which the Court of Appeals dismissed on December 15, 2008 and denied reconsideration on September 11, 2009.
Issues:
- Did the Court of Appeals have jurisdiction to grant the injunctive relief sought by the PHILIPPINE PORTS AUTHORITY?
- Was the petition before the Court of Appeals properly dismissed for forum shopping?
Ruling:
The Court DENIED the Petition for Review and AFFIRMED the Court of Appeals' December 15, 2008 Decision and September 11, 2009 Resolution. The Court ruled that the Court of Tax Appeals had exclusive appellate jurisdiction over the CBAA decision and the power to issue injunctive and other auxiliary reliefs in aid of that jurisdiction, and that the petitioner violated the rule against forum shopping by filing a certiorari petition with the Court of Appeals while its appeal before the Court of Tax Appeals was pending and without submitting the texts of the pleadings to rebut the finding.
Ratio:
Section 7(a)(5) of R.A. No. 1125, as amended by R.A. No. 9282, vests exclusive appellate jurisdiction in the Court of Tax Appeals over CBAA decisions on real property taxation; by virtue of that appellate authority and pursuant to established precedents (including City of Manila v. Grecia‑Cuerdo), the CTA may issue writs and auxiliary remedies necessary to preserve the subject of an appeal and to prevent acts that would frustrate its jurisdiction. Urgency does not displace this statutory exclusivity, and once the CTA acquired jurisdiction the Court of Appeals was precluded from exercising concurrent relief; moreover, the petitioner failed to overcome the Court of Appeals' finding of forum shopping, having not produced the underlying pleadings to show distinct causes of action.
Doctrine:
- The Court of Tax Appeals has exclusive appellate jurisdiction over appeals from the Central Board of Assessment Appeals in real property tax cases under R.A. No. 1125, as amended by R.A. No. 9282.
- A tribunal vested with appellate jurisdiction may issue writs and auxiliary remedies in aid of that jurisdiction, including injunctions to preserve the subject matter.
- Alleged urgency does not divest the tribunal of its exclusive jurisdiction.
- Instituting an action in another court while an appeal is pending in the proper tribunal, with identity of parties and issues, constitutes forum shopping.