Case Digest (G.R. No. 7988) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Young Men’s Christian Association of Manila v. The Collector of Internal Revenue, G.R. No. 7988 decided January 19, 1916, the Young Men’s Christian Association of Manila (YMCA), an institution incorporated under Philippine law in June 1907, paid municipal taxes under protest on its newly constructed building and grounds on Calle Concepcion, Ermita, Manila. The YMCA had obtained a P 170,000 guarantee from its New York foreign committee for a reinforced-concrete structure comprising a three-story central hall, reading rooms, library, lecture rooms, social and game halls, an athletic wing with a gymnasium, swimming pool, bowling alleys, plus 34 rooming apartments on the upper floors. Its charter described purposes “exclusively religious, charitable and educational … not for investment or profit.” The City of Manila assessed the property under Section 48 of the Charter of the City of Manila, asserting it was taxable. The lower court upheld the tax assessment, prompting this a Case Digest (G.R. No. 7988) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- The Young Men’s Christian Association of Manila (“YMCA”) was assessed by the City of Manila for property taxes on its building and grounds under Section 48 of the City Charter.
- YMCA paid the tax of ₱6,221.35 under protest and filed suit for recovery, claiming exemption under its charter. The trial court ruled for the city; YMCA appealed.
- Incorporation and Fundraising
- YMCA originated in Manila with the U.S. Army of Occupation (1898); reorganized as an independent association in February 1905.
- In 1907, the international committee (New York) guaranteed ₱170,000 for construction if local subscribers raised the site and furnishings; by March 15, 1907, local subscriptions totaled ₱83,000. YMCA was formally chartered in June 1907.
- Cornerstone laid July 10, 1908; building dedicated October 20, 1909.
- Building and Grounds Description
- Central Structure (150×45 ft; set 20 m back): three stories housing reception hall, social/game rooms, lecture room, library, reading room, offices, and 34 lodging apartments (14 on 2nd floor, 20 on 3rd), accommodating 64 men.
- Left Wing: kitchen and servants’ quarters.
- Right Wing (68×85 ft, two stories): athletic facilities—bowling alleys, 60×19 ft swimming pool, locker rooms, shower baths; second-floor gymnasium/auditorium (50×85 ft) and roof garden.
- Grounds include tennis courts and a front driveway with iron canopy.
- Institutional Purposes and Activities
- Charter and Constitution: To develop Christian character; improve spiritual, intellectual, social, physical condition of young men; and to hold property exclusively for religious, charitable, educational purposes, not for profit.
- Educational Department: Courses in commercial subjects (stenography, bookkeeping), languages (English, Spanish, Tagalog), Philippine history, public speaking, civil service and consular exam preparation, law, social ethics, political economy.
- Religious Department: Bible study (Life of Christ, Old Testament), religious meetings (Sunday and weekdays), mission study, Bible-teaching methods; nonsectarian but distinctly Christian in spirit.
- Charitable Features: Professors and instructors serve without pay; chief officers not salaried by YMCA; no profit on lodging or instruction; lodging and boarding designed to maintain institutional influence over members, not to generate income.
Issues:
- Whether the YMCA building and grounds are subject to taxation under Section 48 of the Charter of the City of Manila, or are exempt as an institution used exclusively for religious, charitable, and educational purposes and not for profit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)