Saturday, February 11, 2017

CASE DIGEST : NATIONAL POWER CORPORATION vs MUNICIPAL GOVERNMENT OF NAVOTAS

Republic of the Philippines
SUPREME COURT
Manila

THIRD DIVISION

G.R. No. 192300               November 24, 2014

NATIONAL POWER CORPORATION, Petitioner,
vs.
MUNICIPAL GOVERNMENT OF NAVOTAS, SANGGUNIANG BAYAN OF NAVOTAS AND MANUEL T. ENRIQUEZ, in his capacity as Municipal Treasurer of Navotas, Respondents.

FACTS : Petitioner National Power Corporation (NPC) is a government owned and controlled corporation. Respondent Municipal Government of Navotas, is a local government unit, hosting petitioner’s Navotas Power Stations I and II located in the Municipality of Navotas. On the respective dates of November 16, 1988 and June 29, 1992, petitioner entered into a Build-Operate-and-Transfer Project Agreements (BOTs) with Mirant Navotas I Corporation and Mirant Navotas II Corporation. petitioner has the obligation to pay for all taxes, except business taxes, relative to the implementation of the agreements. For the 1st quarter of 2003, petitioner paid respondent Municipality, real property taxes in the amounts of P3,382,715.88 and P4,973,869.83 for the MNC-I and MNC-II power stations, respectively. After the said quarter, petitioner stopped paying the real property taxes, claiming exemption from payment thereon pursuant to Section 234(c) of the Local Government Code (LGC) of 1991. On May 25, 2005, MNC-II received four notices from respondent Municipal Treasurer informing MNC-I and MNC-II of their real property tax delinquencies for the 2nd, 3rd, and 4th quarters of calendar year 2003 and for the calendar years 2004 and 2005. On November 21, 2005, a Warrant of Levy was received from respondent Municipal Treasurer. On December 16, 2005, petitioner filed before the Regional Trial Court (RTC) of Malabon City, a Petition for Declaratory Relief, Annulment of Notice of Delinquency, Warrant of Levy, and Notice of Sale with prayer for the issuance of a Writ of Preliminary Injunction and Temporary Restraining Order (TRO). Petitioner’s application for the issuance of a TRO was denied by the RTC. Respondents proceeded withthe scheduled public auction. Considering that there were no bidders for the purchase of the subject properties, the same were forfeited in favor of respondent Municipality. Petitioner filed an amended petition before the RTC seeking to declare as null and void the public auction. The RTC denied the petition on May 23, 2007. a Petition for Review with application for Temporary Restraining Order and/or Order of Suspension of Collection and Writ of Preliminary Injunctionwas seasonably filed with this Court though registered mail on July 27, 2007 and received on August 2, 2007. In a Decision promulgated on July 18, 2008, the Second Division dismissed the Petition and sustained the RTC’s Decision dated May 23, 2007. Petitioner’s Motion for Reconsideration filed on August 6, 2008 was likewise denied in a Resolution dated January 9, 2009. petitioner filed a petition before the CTA En Banc. In a Decision dated March 1, 2010, the CTA En Banc affirmed the CTA Second Division’s

ISSUE : the issue is whether or not the CTA Second Division has jurisdiction to review the decision of the RTC which concerns a petition for declaratory relief involving real property taxes

HELD: Indeed, the CTA, sitting as Division, has jurisdiction to review by appeal the decisions, rulings and resolutions of the RTC over local tax cases, which includes real property taxes. This is evident from a perusal of the Local Government Code (LGC) which includes the matter of Real Property Taxation under one of its main chapters. We, therefore, disagree with the conclusion of the CTA En Banc that real property taxes have always been treated by our laws separately from local taxes. Based on the foregoing, the general meaning of "local taxes" should be adopted in relation to Paragraph (a)(3) of Section 7 of R.A. 9282, which necessarily includes real property taxes. Second, as correctly pointed out by petitioner, when the legality or validity of the assessment is in question, and not its reasonableness or correctness, appeals to the LBAA, and subsequently to the CBAA, pursuant to Sections 22614 and 22915 of the LGC, are not necessary.

Stated differently, in the event that the taxpayer questions the authority and power of the assessor to impose the assessment, and of the treasurer to collect the real property tax, resort to judicial action may prosper. Although as a rule, administrative remedies must first be exhausted before resort to judicial action can prosper, there is a well-settled exception in cases where the controversy does not involve questions of fact but only of law. In the present case, the parties, even during the proceedings in the lower court on 11 April 1994, already agreed "that the issues in the petition are legal", and thus, no evidence was presented in said court., if a taxpayer disputes the reasonableness of an increase in a real estate tax assessment, he is required to "first pay the tax" under protest. Otherwise, the city or municipal treasurer will not act on his protest. In the case at bench, however, the petitioners are questioning the very authority and power of the assessor, acting solely and independently, to impose the assessment and of the treasurer to collect the tax. These are not questions merely of amounts of the increase in the tax but attacks on the very validity of any increase. Accordingly, if the only issue is the legality or validity of the assessment – a question of law – direct recourse to the RTC is warranted. the issue is clearly legal given that it involves an interpretation of the contract between the parties vis-à-vis the applicable laws, i.e.,which entity actually, directly and exclusively uses the subject machineries and equipment. the CT A En Banc erred in dismissing the petition for review en bane, and affirming the CTA Second Division’s position that the RTC has no jurisdiction over the instant case for failure of petitioner to exhaust administrative remedies which resulted in the finality of the assessment

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