Case Digest (G.R. No. 214044) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The University of the Philippines (UP) is the registered owner of a 985,597-sqm parcel of land along Commonwealth Avenue, Diliman, covered by TCT No. RT-107350 (192689). On 27 October 2006, UP entered into a Contract of Lease with Development Obligations with Ayala Land, Inc. (ALI) over a 380,630-sqm portion, stipulating that UP would pay real property tax on the land while ALI would pay tax on improvements. On 23 August 2012, the City Assessor of Quezon City issued a Notice of Assessment to ALI under Sections 205(d) and 234(a) of the Local Government Code (LGC), reclassifying the land with an assessed value of ₱499,500,000 effective 2009. Thereafter, the City Treasurer issued statements of delinquency addressed to UP North Property Holdings, Inc.—₱78,970,950 for 2009-2012 and early 2012, and later ₱102,747,150 for 2009-2013—each time citing the same LGC provisions. Without prior notice of assessment, on 27 May 2014 the City Treasurer directly sent UP a Statement of Delinquency ... Case Digest (G.R. No. 214044) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- The University of the Philippines (UP), registered owner of a 985,597 sqm parcel along Commonwealth Avenue, Diliman, Quezon City (TCT No. RT-107350), entered into a Contract of Lease with Development Obligations on 27 October 2006, leasing 380,630 sqm to Ayala Land, Inc. (ALI) (the “Technohub”).
- UP filed a petition for certiorari and prohibition under Rule 65 against the City Treasurer of Quezon City to annul:
- The Statement of Delinquency dated 27 May 2014 (₱106,992,990.00 for 2009–2013 & 1Q 2014), and
- The Final Notice of Delinquency dated 11 July 2014 (₱117,182,700.00 for 2009–2014 3Q),
- Assessment and Delinquency Notices
- Notice of Assessment (23 August 2012) served on ALI reclassifying and assessing the property at ₱499,500,000.00 effective 2009 under LGC §§ 205(d) & 234(a).
- Statements of Delinquency issued by the City Treasurer to UP North Property Holdings, Inc.:
- 5 December 2012 (₱78,970,950.00 for 2009–2012 3Q),
- 24 September 2013 (₱102,747,150.00 for 2009–2013 3Q).
- First delinquency demand directed to UP on 27 May 2014 without prior assessment. UP’s 13 June 2014 letter objected, citing RA 9500 exemptions and a BLGF opinion that ALI is the liable party.
- Final Notice of Delinquency on 11 July 2014 for ₱117,182,700.00. UP filed the petition within 60 days.
- Procedural History
- 29 September 2014: Temporary Restraining Order issued; City Treasurer ordered to comment.
- Multiple resolutions in 2015–2016 imposing fines (₱1,000; ₱2,000) for failure to file comment.
- 29 September 2016: Acting Assistant City Treasurer filed Comment contesting jurisdiction, real-party status, failure to file Motion for Reconsideration, and asserting ALI’s liability under LGC and Supreme Court precedents.
- 20 February 2017: UP filed its Reply.
- Governing Law and Contract Provisions
- Lease contract clauses:
- Permanent improvements owned by ALI during the lease term.
- UP to pay real estate tax on land; ALI to pay tax on improvements.
- Republic Act No. 9500 (UP Charter of 2008):
- Sec 22 – Grants land and income for UP’s use;
- Sec 25(a) – All revenues and assets used for educational purposes or in support thereof are exempt from all taxes and duties;
- Sec 27 – Doubts resolved in favor of UP’s academic freedom and fiscal autonomy;
- Sec 30 – Repeals inconsistent laws.
- Local Government Code of 1991:
- Sec 133(o) – Exempts national government and instrumentalities from local taxes;
- Sec 205(d) & 234(a) – Taxable when beneficial use of government-owned property is granted to a taxable person.
Issues:
- Is the University of the Philippines liable for real property tax on the parcel covered by TCT No. RT-107350 (192689) leased to Ayala Land, Inc.?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)