Case Digest (G.R. No. 137378) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Eusebio Villanueva, et al. v. City of Iloilo, G.R. No. L-26521, decided December 28, 1968 under the 1935 Philippine Constitution, spouses Eusebio Villanueva and Remedios Sian Villanueva (plaintiffs-appellees) owned five tenement houses in Iloilo City containing 43 apartments, while other appellees owned ten additional apartments. Each unit featured a street-facing door, with ground floors used as shops and upper floors as residences. On January 15, 1960, the Iloilo City Municipal Board enacted Ordinance 11, series of 1960, imposing a municipal license tax on operators of tenement houses ranging from ₱5.00 to ₱30.00 per door annually. Between 1960 and 1964, the City collected ₱5,824.30 from the Villanuevas and ₱1,317.00 from the other appellees, despite their payment of real estate and national income taxes. On July 11, 1962, and April 24, 1964, the appellees filed a complaint and amended complaint in the Court of First Instance of Iloilo, contending the ordinance was ultra vi Case Digest (G.R. No. 137378) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Prior Ordinance and Litigation
- On September 30, 1946 the Municipal Board of Iloilo City enacted Ordinance 86 imposing annual license fees on tenement houses (P25 per “casa de vecindad,” P24 per street‐front apartment on J.M. Basa, Isnart and Aldeguer, P12 elsewhere).
- In City of Iloilo v. Remedios S. Villanueva et al. (L-12695, March 23, 1959), the Supreme Court declared Ordinance 86 ultra vires for lack of charter authority to tax tenement houses.
- Enactment of Ordinance 11, series of 1960
- Believing Republic Act 2264 (Local Autonomy Act, effective June 19, 1959) conferred taxing power, the Municipal Board passed Ordinance 11 on January 15, 1960.
- Ordinance 11 imposed a “municipal license tax on persons engaged in the business of operating tenement houses,” defined tenement houses as buildings divided into separate apartments or accessorias, and set five graduated schedules (I–V) based on materials, location, and commercial use. It also prescribed penalties (fine up to P200 or imprisonment up to 6 months) for non‐payment.
- Plaintiffs’ Properties and Procedural History
- Spouses Eusebio Villanueva and Remedios S. Villanueva owned five tenement houses (43 apartments) in Iloilo City; other appellees owned ten more. Each apartment had a street door and was rented by merchants.
- From 1960–1964 the City collected P5,824.30 from the Villanuevas and P1,317.00 from the other appellees. Eusebio Villanueva also paid real estate taxes and operated rental properties in other cities without similar tenement taxes.
- On July 11, 1962 (and amended April 24, 1964) the appellees sued to declare Ordinance 11 invalid—beyond municipal power under RA 2264, unconstitutional for non‐uniform taxation and unequal protection—and prayed for refund.
- Lower Court Decision
- On March 30, 1966 the Court of First Instance declared Ordinance 11 illegal: (a) RA 2264 did not authorize tenement taxes, (b) the penal clause was oppressive and unreasonable, (c) it imposed double and treble taxation, and (d) it violated uniformity.
- The court ordered the City to refund all amounts collected under the ordinance.
Issues:
- Authority
- Whether under Republic Act 2264 the City had power to impose a tenement‐house license tax.
- Double Taxation
- Whether Ordinance 11 imposed prohibited double or multiple taxation.
- Penal Clause
- Whether the fine and imprisonment for non‐payment rendered the ordinance oppressive or unconstitutional.
- Uniformity
- Whether the classification or application of the tenement tax violated the uniformity requirement.
- Res Judicata
- Whether the 1959 decision in L-12695 bars enforcement of Ordinance 11.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)