Case Digest (G.R. No. 124642) Core Legal Reasoning Model
Facts:
This case involves petitioners Conrado L. Tiu, Juan T. Montelibano Jr., and Isagani M. Jungco who challenged the constitutionality of Executive Order No. 97-A (EO 97-A) dated June 19, 1993, which limited the grant and enjoyment of tax and duty incentives authorized under Republic Act No. 7227 (RA 7227) to business enterprises and residents within the "secured area" of the Subic Special Economic Zone (SSEZ), excluding those living outside the fenced-in area but still within the zone. RA 7227, enacted on March 13, 1992, created the Subic Special Economic Zone comprising the City of Olongapo, Municipality of Subic, the lands occupied by the Subic Naval Base based on the 1947 Military Bases Agreement, and parts of adjacent municipalities. The law granted special privileges within the zone, including tax and duty-free importations and a reduced gross income tax payment scheme for businesses. EO 97 clarified that only raw materials, capital goods, and equipment imported by businesses ... Case Digest (G.R. No. 124642) Expanded Legal Reasoning Model
Facts:
Background of the Case
On March 13, 1992, Republic Act No. 7227 (RA 7227) was enacted, creating the Subic Special Economic Zone (SSEZ) and granting tax and duty incentives to businesses and residents within the zone. The law aimed to accelerate the conversion of military reservations, particularly the former Subic Naval Base, into productive economic uses.
Executive Orders Issued
On June 10, 1993, President Fidel V. Ramos issued Executive Order No. 97 (EO 97), clarifying that tax and duty-free importations would apply only to raw materials, capital goods, and equipment brought into the SSEZ. On June 19, 1993, EO 97-A was issued, limiting the tax-and-duty-free privileges to the "secured area" or the fenced-in former Subic Naval Base, excluding the broader areas of Olongapo City and Subic Municipality.
Petitioners' Challenge
The petitioners, residents of Olongapo City and Subic Municipality, challenged EO 97-A before the Supreme Court, arguing that it violated their right to equal protection under the law. They contended that the Executive Order discriminated against them by granting privileges only to those within the secured area while denying the same to residents outside it.
Procedural History
The Supreme Court referred the case to the Court of Appeals, which upheld the constitutionality of EO 97-A, ruling that it was consistent with the intent of RA 7227. The petitioners then sought a review of the Court of Appeals' decision.
Issues:
The primary issue is whether Executive Order No. 97-A violates the equal protection clause of the Constitution by limiting the application of tax and duty incentives to the secured area of the Subic Special Economic Zone, thereby excluding residents outside the fenced-in territory.Ruling:
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Ratio:
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