Case Summary (G.R. No. L-35131)
Background of the Case
The case concerns a petition for review on certiorari filed by Belen C. Figuerres challenging the dismissal of her prohibition suit by the Court of Appeals. Figuerres sought to prevent the enforcement of certain municipal ordinances that revised the fair market values of real properties in Mandaluyong and established the assessment levels for taxation.
Ordinances and Assessment Details
In 1993, Figuerres received a notice of assessment for her property based on several city ordinances. The assessments were framed within the context of Ordinance Nos. 119, 125 (both from 1993), and Ordinance No. 135 from 1994, which provided the schedule for fair market values and applicable assessment levels for properties within the city.
Legal Challenges and Claims
Figuerres claimed the ordinances were invalid due to alleged procedural deficiencies, specifically asserting that they were adopted without necessary public hearings and without prior compliance with rules mandated by the Department of Finance. Her lawsuit was founded on the premise that these procedural lapses rendered the ordinances ineffective.
Decision by the Court of Appeals
The Court of Appeals affirmed the validity of the ordinances and dismissed the petition. The court concluded that the department's prior approval was not necessary under the Local Government Code of 1991, and that the ordinances had been enacted legitimately. The court underscored a lack of evidence from Figuerres to substantiate her claims regarding public hearings and compliance with regulatory procedures.
Exhaustion of Administrative Remedies
The appellate court elaborated on the doctrine of exhaustion of administrative remedies. It highlighted that before filing a lawsuit, taxpayers must first utilize the administrative processes available to them under the Local Government Code, specifically referring to Sections 187, 226, and 252 of Republic Act No. 7160. Figuerres’ failure to pursue these administrative remedies deemed her petition premature.
Public Hearing Requirement
Although the law mandates public hearings before enacting tax ordinances, the burden of proof rested on Figuerres to demonstrate that no hearings occurred. The court noted that her bare assertions were insufficient to overturn the presumption of validity favoring the enacted ordinances.
Publication and Posting of Ordinances
The ruling clarified the requirements for ordinances concerning the publishing and posting of the schedule of fair market values and tax ordinances, emphasizing that while they should be publicly disseminated, Figuerres had not presented adequate evidence to challenge their compliance with these requirements.
Compliance with Department of Finance Regulations
The court dismiss
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Case Overview
- This case involves a petition for review on certiorari regarding the decision of the Court of Appeals dated February 8, 1995.
- The petitioner, Belen C. Figuerres, sought to prevent the enforcement of certain ordinances related to the assessment of real property in Mandaluyong.
- The ordinances in question revised the schedule of fair market values and assessment levels for various classes of real property.
Background Information
- Belen C. Figuerres is the owner of a parcel of land located on Amarillo Street, Barangay Mauway, City of Mandaluyong, covered by Transfer Certificate of Title No. 413305.
- In 1993, Figuerres received a notice of assessment from the municipal assessor, detailing a residential property assessment based on Ordinance Nos. 119, 125 (both from 1993), and Ordinance No. 135 (from 1994).
Ordinances in Question
- Ordinance No. 119 (1993): Established a schedule of fair market values for different classes of real property.
- Ordinance No. 125 (1993): Set forth the assessment levels for these properties.
- Ordinance No. 135 (1994): Amended Ordinance No. 119, allowing only one-third of the increase in market values for residential lands to be implemented in 1994, 1995, and 1996.
Legal Challenge
- Figuerres filed a prohibition suit against the municipal officials, arguing that the ordinances were invalid due to lack of public hearings, prior publication, and failure to comply with Department of Finance guidelines.
- The Court of Appeals dismissed Figuerres's petition, stating that the city council had the authority to enact these ordinances without Departm