G.R. No. 208788 - Quezon City Government vs. Manila Seedling Bank Foundation, Inc.

Petitioners: Quezon City Government (represented by Mayor Herbert M. Bautista and CPDO Tomasito L. Cruz), and Manila Seedling Bank Foundation, Inc. (Foundation), represented by its president and chairman.
Cases: Two consolidated cases - (a) First Case (G.R. No. 208788): City challenged RTC's decision granting Foundation's petition for prohibition against enforcement of Quezon City's zoning ordinance affecting Foundation's property; (b) Second Case (G.R. No. 228284): Foundation appealed trial court and Court of Appeals’ dismissal of its petition for prohibition due to alleged lack of capacity to sue.

Subject Property: 7-hectare land in Quezon City, originally part of 120-hectare National Government Center site owned by National Housing Authority (NHA) under Proclamation No. 481 (1968).
Proclamation No. 1670 (1977): Reserved the 7-hectare property for use by the Foundation, granting usufructuary rights subject to private rights.
The Foundation used the land for environmental projects including plant nursery and related activities.

Quezon City enacted Ordinance No. SP-918 (2000), amended by Ordinance No. SP-1369 (2003), classifying the Foundation's property mostly as Metropolitan Commercial Zone and partly as Institutional Zone.
Certificate of Non-Conformance issued to the Foundation (2008-2011) allowed non-conforming use with conditions including phasing out in 10 years.
City denied renewal of locational clearance in 2012, resulting in the failure to renew the Foundation's business permit.

Foundation filed petition for prohibition with application for injunction to prevent enforcement of the zoning ordinance on its property; trial court granted relief, declaring parts of ordinance affecting Foundation as unconstitutional and ultra vires.
City filed petition for review challenging such relief; also raised that Foundation lacked legal personality due to SEC revocation of registration in 2002.
Concurrently, after alleged tax delinquency, city auctioned and seized property; Foundation filed another petition for prohibition contesting unlawful eviction.

City argued Foundation had no capacity to sue because its SEC registration was revoked in 2002; Foundation argued revocation was not final and was later set aside.
Trial court and Court of Appeals initially dismissed petition due to lack of capacity; later, SEC granted reinstatement of Foundation's corporate status, recognized as retroactive.

Property owned by NHA, a government corporation exempt from payment of real estate taxes.
Foundation, as beneficial usufructuary, liable for taxes.
City foreclosed and sold property to satisfy purported tax delinquency of Foundation.

Whether the City’s direct appeal by petition for review on certiorari to the Supreme Court is procedurally proper.
Whether the Foundation had legal capacity to sue despite revocation of its SEC registration and whether the City is estopped from denying such capacity.
Whether the Foundation could assail the constitutionality and validity of the Quezon City Zoning Ordinance through a petition for prohibition.
Whether the City could validly assess realty taxes on the NHA-owned property and foreclose and seize the property for non-payment.
Whether the City could reclassify or regulate the use of the property subject to Foundation’s usufruct through the Zoning Ordinance.