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Manila International Airport Authority Vs. City of Pasay, et al. [ SEPARATE OPINION ]

MANILA INTERNATIONAL AIRPORT AUTHORITY, Petitioner, versus CITY OF PASAY, SANGGUNIANG PANGLUNGSOD NG PASAY, CITY MAYOR OF PASAY, CITY TREASURER OF PASAY, and CITY ASSESSOR OF PASAY, Respondents.

G.R. No. 163072 | 2009-04-02

SEPARATE OPINION


NACHURA, J.:

Are airport properties subject to real property tax? The question seriously begs for a definitive resolution, in light of our ostensibly contradictory decisions[1] that may have generated no small measure of confusion even among lawyers and magistrates.

Hereunder, I propose a simple, direct and painless approach to arrive at an acceptable answer to the question.

I.

Real property tax is a direct tax on the ownership of lands and buildings or other improvements thereon, not specially exempted, and is payable regardless of whether the property is used or not, although the value may vary in accordance with such...