G.R. No. L-4376 - Association of Customs Brokers, Inc. vs. Municipal Board

Under Section 70-b of Act No. 3992, no fees may be demanded for the operation of motor vehicles, except for property tax and those specifically provided in the Act.
This provision is comprehensive and applies to all motor vehicles, limiting the power of the City of Manila to impose additional taxes.
The interpretation of Section 18 of the City Charter must align with the Motor Vehicle Law, indicating that the City can only impose property tax on motor vehicles.

Ordinance No. 3379, while labeled as a property tax, functions as a license tax aimed at generating revenue for street and bridge maintenance.
The Motor Vehicle Law prevents municipalities from imposing duplicate fees for the same purpose, which the ordinance appears to circumvent by mislabeling the tax.
The ordinance's intent to raise funds for specific public works contradicts the provisions of the Motor Vehicle Law.

The ordinance violates the constitutional requirement for uniformity in taxation by imposing a tax on all motor vehicles without distinction.
It does not differentiate between vehicles for hire and private vehicles, nor does it account for vehicles registered outside Manila that use the city's roads.
This lack of distinction creates an inequality, as vehicles temporarily using Manila's streets are not subjected to the same tax burden, rendering the ordinance unconstitutional.

The petition for declaratory relief was filed by the Association of Customs Brokers, Inc. and G. Manlapit, Inc. to challenge the validity of Ordinance No. 3379.
The respondents argued that the ordinance was a lawful property tax under the City’s Revised Charter, but the court found it to be a license tax beyond the Municipal Board's authority.
The court emphasized the need to interpret the nature and purpose of the tax, concluding that it was eff...continue reading