Case Digest (G.R. No. 248033)
Facts:
- The Provincial Government of Cavite and the Provincial Treasurer of Cavite (petitioners) are in a legal dispute with CQM Management, Inc. (respondent), the successor-in-interest of Philippine Investment One (SPV-AMC), Inc. (PI One).
- On November 25, 2014, CQM Management, Inc. filed a petition for injunction to stop the auction of properties due to unpaid real property taxes by Maxon Systems Philippines, Inc. (Maxon) and Ultimate Electronic Components, Inc. (Ultimate).
- PI One had acquired non-performing loans from Rizal Commercial Banking Corporation (RCBC) secured by real estate mortgages over properties in the Philippine Economic Zone Authority (PEZA), Rosario, Cavite.
- These properties were sold to PI One and later to CQM Management, Inc. through a Deed of Assignment.
- The Provincial Treasurer of Cavite issued a tax assessment and warrant of levy against Maxon and Ultimate for unpaid real property taxes, leading to a scheduled public auction.
- The Regional Trial Court (RTC) of Makati City issued a preliminary writ of injunction, preventing the auction.
- The RTC ruled in favor of CQM Management, Inc., stating that the properties were exempt from real property taxes under Section 24 of Republic Act (RA) 7916, as amended by RA 8748.
- The Court of Appeals (CA) affirmed the RTC's decision, leading to the petitioners' appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- No, CQM Management, Inc. is not liable for the unpaid real property taxes on the properties previously owned by Maxon and Ultimate.
- Yes, the properties located in the PEZA are exempt from real property taxes under RA 7916, as amended by RA 8748...(Unlock)
Ratio:
- The Supreme Court denied the petition, affirming the CA's decision.
- The Court held that the liability for real property taxes generally rests on the owner of the property at the time the tax accrues.
- CQM Management, Inc. became the owner of the properties only in 2014, after the redemption periods had lapsed.
- It would be unjust and contrary to law to impose the real property taxes for the years 2000-2013 (Maxon property) and 1997-2013 (Ultimate property) on CQM Management, Inc., as it was neither the owner nor the entity with actual or beneficial use of the properties during those periods.
- The Court ruled that the properties are exempt from real property taxes under Section 24 of RA 7916, as...continue reading
Case Digest (G.R. No. 248033)
Facts:
The case involves the Provincial Government of Cavite and the Provincial Treasurer of Cavite (petitioners) against CQM Management, Inc. (respondent), which is the successor-in-interest of Philippine Investment One (SPV-AMC), Inc. (PI One). On November 25, 2014, CQM Management, Inc. filed a petition for injunction with a prayer for a temporary restraining order and preliminary injunction to prevent the auction of properties due to unpaid real property taxes by Maxon Systems Philippines, Inc. (Maxon) and Ultimate Electronic Components, Inc. (Ultimate). PI One had acquired non-performing loans from Rizal Commercial Banking Corporation (RCBC) secured by real estate mortgages over properties located in the Philippine Economic Zone Authority (PEZA), Rosario, Cavite. These properties were later sold to PI One and subsequently to CQM Management, Inc. through a Deed of Assignment. The Provincial Treasurer of Cavite issued a tax assessment and warrant of levy against Maxon and Ultimate for unpaid real property taxes, leading to a scheduled public auction. However, the Regional Trial Court (RTC) of Makati City issued a preliminary writ of injunction, preventing the auction. The RTC ruled in favor of CQM Management, Inc., stating that the properties were exempt from real property taxes under Section 24 of Republic Act (RA) 7916, as amended by RA 8748. The Court of Appeals (CA) affirmed the RTC's decision, leading to the petitioners' appeal to the Supreme Court.