G.R. No. 21106 - Tiu Siuco vs. Habana

Case Summary (G.R. No. 21106)

Applicable Law and Grounds for Petition

The Government Service Insurance System challenged the decision and resolution of the Court of Appeals which dismissed its petition for annulment of judgments rendered by the Regional Trial Courts of Iloilo City pertaining to cadastral cases. GSIS asserted that the assessments and levies of real property taxes against its properties were void based on RA 8291, claiming tax exemption. They also contended that due process was violated due to the lack of notice regarding the tax assessment proceedings.

Background of Properties and Legal Proceedings

Rosalina Francisco acquired the two parcels of land—specifically TCT No. 41681 and TCT No. 48580—through a public auction after the original owners, GSIS, failed to redeem these properties after the one-year redemption period. The issuance of new TCTs was granted in two separate orders by the RTCs of Iloilo City, as no opposition was raised against the petitions filed by Francisco, and these orders became final and executory.

Arguments Presented by Petitioner

GSIS contended that it was exempt from paying real property taxes based on Section 39 of RA 8291, which outlines its tax-exempt status as an entity. It argued that the tax assessments on its properties were improper and lacked due process, claiming the assessments and subsequent auction sales couldn't be executed without proper notification to GSIS as the registered owner.

Rulings of the Court of Appeals

The Court of Appeals ruled that the tax exemption GSIS posited was inapplicable as per Section 234(a) of the Local Government Code (RA 7160). The appellate court established that once GSIS conveyed its properties to private individuals, those properties were no longer entitled to tax exemption. The CA dismissed GSIS’s claims regarding denial of due process, stating that the assessments and levies were carried out legally.

Supreme Court's Decision

The Supreme Court upheld the ruling of the Court of Appeals, determining that the exemption GSIS claimed under its charter did not extend to the properties involved in the auction. The Court noted that once the properties were conveyed, their tax obligations were activated. The maintained tax liability stemmed from GSIS's prior ownership, which had ceased upon sale to private individuals.

Consideration of Legislative Intent

The Supreme Court rejected GSIS's argument that RA 8291 extinguished Section 234(a) of the LGC, ruling that no explicit repeal of the latter law was present in RA 8291. In cases of legislative conflict, the intent to repeal must be explicitly indicated, which was deemed absent in this case; thus the statutes were interpreted to coexist without direct contradiction.

Principles Established in Jurispruden