Case Summary (G.R. No. 7988)
Petitioner
Young Men’s Christian Association of Manila
Respondent
Collector of Internal Revenue, City of Manila
Key Dates
- 1898: YMCA arrives with the U.S. army of occupation
- February 1905: Independent Manila YMCA organized
- February–March 1907: Local fundraising (P 83,000 subscribed; P 170,000 guaranteed)
- June 1907: Incorporation and charter granted
- January 8, 1908: Building contract awarded
- July 10, 1908: Cornerstone laid
- October 20, 1909: Building dedicated
- January 19, 1916: Decision rendered
Applicable Law
Section 48 of the City of Manila Charter exempts property “used exclusively for religious, charitable, scientific or educational purposes, and not for investment or profit.” As the decision predates 1990, the exemption is judged under this charter rather than the 1987 Constitution.
Property Description
The YMCA occupies a reinforced-concrete complex on Calle Concepcion, Ermita, comprising:
- A three-story central building with reception and social halls, game rooms, lecture room, library, reading room, and 34 residential apartments.
- A kitchen and servants’ quarters adjacent on the left.
- An athletic wing on the right housing locker rooms, shower baths, a 60×19-foot swimming pool, bowling alleys, a gymnasium/auditorium, and a roof garden.
Association Purposes
Its charter and constitution specify exclusive religious, charitable, and educational purposes: to build Christian character, and to hold property solely for these objectives, “not for investment or profit.” Activities include low-cost academic and vocational instruction, Bible study and worship services, mission education, and moral and physical training.
Tax Exemption Claim
YMCA challenged the City’s tax assessment, asserting total exemption under Section 48. The City countered that lodging, boarding, and athletic facilities constituted “business” uses disqualified by the charter’s “not for … profit” requirement.
Court’s Analysis
- Combined Purposes Permitted: The charter does not require exclusive devotion to a single purpose; a lawful combination of religious, charitable, and educational uses suffices.
- Educational and Religious Departments: Courses range from bookkeeping and languages to law and consular-service preparation; religious work encompasses Bible classes and services, fostering a distinctly Christian atmosphere.
- Charitable Features: Volunteer instructors and unpaid officers, absence of profit on services, and disregard of depreciation in fee calculations demonstrate charitable intent.
- Lodging and Boarding: Room and board serve institutional influence over members rather than profit. They reinforce moral oversight and continuity of the YMCA’s objectives.
- Dedication of Property: Every room and facility is devoted exclusively to organizational purposes. Precedents under
Case Syllabus (G.R. No. 7988)
Procedural History
- G.R. No. 7988; reported at 33 Phil. 217; decided January 19, 1916.
- The City of Manila, through its Collector of Internal Revenue, assessed the YMCA building and grounds for taxation under Section 48 of the City Charter.
- The Young Men’s Christian Association of Manila paid the tax under protest and filed suit to recover the amount, claiming statutory exemption.
- Trial court ruled in favor of the City of Manila; the Association appealed to the Supreme Court.
- Supreme Court reversed the lower court’s decision and remanded with instructions to enter judgment for the Association in the amount of P 6,221.35, without costs.
Factual Background
- YMCA origins in Manila date to 1898 with the Army of Occupation; independent local association organized in February 1905.
- In January 1907, John R. Mott of the International Committee guaranteed P 170,000 for construction, contingent on local subscription.
- Local fund‐raising (February–March 1907) secured P 83,000 from nearly 1,000 contributors.
- The Association was formally incorporated under Philippine law in June 1907.
Architectural and Operational Details
- The property consists of a main three‐story building flanked by a kitchen/servants’ quarters (left) and an athletic wing (right).
- Construction: reinforced concrete, steel‐trussed roof, interlocking red tiles.
- Main building dimensions: 150×45 ft; set 20 m back from the sidewalk; features an iron canopy over the driveway.
- Ground‐floor layout: large reception hall; public and private offices; reading, writing and library rooms (~30×30 ft each); billiard room; restaurant; veranda overlooking tennis courts.
- Athletic wing: two stories, 68×85 ft; ground floor houses toilet, showers, locker rooms, 60×19 ft cement‐lined swimming pool, and bowling alleys; second floor is a 50×85 ft gymnasium/