Case Digest (G.R. No. 191109) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines, represented by the Philippine Reclamation Authority (PRA) v. City of Parañaque, G.R. No. 191109, decided on July 18, 2012, the PRA challenged real property tax assessments on several reclaimed parcels in Parañaque City. The lands in question had been reclaimed and titled in PRA’s name under Original Certificates of Title Nos. 180, 202, 206, 207, 289, 557, 559 and Transfer Certificates of Title Nos. 104628, 7312, 7309, 7311, 9685, 9686. On February 19, 2003, City Treasurer Liberato M. Carabeo issued warrants of levy for delinquent real property taxes for tax years 2001 and 2002. PRA filed a petition for prohibition with a prayer for TRO and injunction before RTC Branch 195, Parañaque City. The RTC denied the TRO on April 3, 2003, and, after the properties were auctioned on April 7, 2003, denied preliminary injunction as moot on April 25, 2003. On August 3, 2009, PRA sought leave to file a supplemental petition to void the tax assessments, levy, auc Case Digest (G.R. No. 191109) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- The Republic of the Philippines, represented by the Philippine Reclamation Authority (PRA), filed a petition for review on certiorari under Rule 45, challenging a January 8, 2010 RTC, Branch 195, Parañaque City order declaring PRA a government-owned and controlled corporation (GOCC) and thus liable for real property taxes.
- Creation and Evolution of PRA
- Presidential Decree No. 1084 (Feb. 4, 1977) created the Public Estates Authority (PEA) to coordinate reclamation and management of government lands.
- Executive Order No. 525 (Feb. 14, 1979) designated PEA as the primary reclamation agency; EO No. 380 (Oct. 26, 2004) transformed PEA into PRA.
- PRA reclaimed foreshore and offshore areas of Manila Bay, including lands in Parañaque City, and obtained transfer and original certificates of title.
- Proceedings Below
- On February 19, 2003, the Parañaque City Treasurer issued warrants of levy for alleged delinquent real property taxes (2001–2002) on PRA’s reclaimed properties.
- PRA sought prohibition, TRO, and preliminary injunction before the RTC; TRO and injunction were denied, and an auction was held April 7, 2003, with certificates of sale issued.
- On August 3, 2009, PRA moved to file a supplemental petition to annul the tax assessment, levy, auction sale, and certificates of sale. The RTC denied relief on January 8, 2010, ruling PRA a GOCC under P.D. No. 1084, subject to real property tax per Section 193 of R.A. 7160.
- Petition to the Supreme Court
- PRA’s Grounds for Certiorari
- That PRA, as an incorporated instrumentality of the national government, is exempt from real property tax under Sections 234(a) and 133(o) of R.A. 7160 vis-à-vis Manila International Airport Authority v. CA.
- That reclaimed lands remain part of the public domain and thus are tax-exempt.
- Parties’ Contentions
- PRA: Not a GOCC under Administrative Code Sec. 2(13) or Constitution Art. XII, Sec. 16; lacks dividend‐distribution power and members; serves an essential public function; exempt under R.A. 7160.
- City of Parañaque: PRA consistently represented itself as a GOCC, has capital stock, was created by special charter, and is subject to Section 193 of R.A. 7160 withdrawing GOCC tax exemptions.
Issues:
- Whether PRA is a GOCC or an exempt government instrumentality under the Administrative Code and Constitution, and thus whether it is liable for real property tax.
- Whether the reclaimed lands remain part of the public domain and are consequently exempt from real property taxation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)