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City of Manila, Lim and Acevedo vs. Colet

CITY OF MANILA, HON. ALFREDO S. LIM, as Mayor of the City of Manila, and ANTHONY Y. ACEVEDO, City Treasurer, Petitioners, - versus - HON. ANGEL VALERA COLET, as Presiding Judge, Regional Trial Court of Manila (Br. 43), and MALAYSIAN AIRLINE SYSTEM, Respondents. G.R. No. 120051 MAERSK-FILIPINAS, INC., AMERICAN PRESIDENT LINES, LTD., FLAGSHIP TANKERS CORP., CORE INDO MARITIME CORP., and CORE MARITIME CORP., Petitioners, - versus - CITY OF MANILA, MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA,1 SANGGUNIANG PANLUNGSOD and CITY TREASURER ANTHONY ACEVEDO, Respondents. G.R. No. 121613 EASTERN SHIPPING LINES, INC., Petitioner, - versus - CITY COUNCIL OF MANILA, THE MAYOR OF MANILA and THE CITY OF MANILA, Respondents. G.R. No. 121675 WILLIAM LINES, INC., NEGROS NAVIGATION CO., INC., LORENZO SHIPPING CORPORATION, CARLOS A. GOTHONG LINES, INC., ABOITIZ SHIPPING CORPORATION, ABOITIZ AIR TRANSPORT CORPORATION, ABOITIZ HAULERS, INC., and SOLID SHIPPING LINES CORPORATION, Petitioners, - versus - REGIONAL TRIAL COURT OF MANILA, BRANCH 32, CITY OF MANILA, MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA, SANGGUNIANG PANLUNGSOD, and CITY TREASURER ANTHONY ACEVEDO, Respondents. G.R. No. 121704 PNOC SHIPPING AND TRANSPORT CORPORATION, Petitioner, - versus - HON. JUAN T. NABONG, JR., Presiding Judge, Regional Trial Court of Manila, Branch 32; THE CITY OF MANILA; MAYOR ALFREDO LIM; VICE MAYOR LITO ATIENZA; SANGGUNIANG PANLUNGSOD, and CITY TREASURER ANTHONY ACEVEDO , Respondents G.R. Nos. 121720-28 MAERSK-FILIPINAS, INC., AMERICAN PRESIDENT LINES, SEA-LAND SERVICES, INC., OVERSEAS FREIGHTERS SHIPPING, INC., DONGNAMA SHIPPING CO., LTD., FLAGSHIP TANKERS, CORE INDO MARITIME CORP., CORE MARITIME CORP., and EASTERN SHIPPING LINES, INC., Petitioners, - versus - CITY OF MANILA, HON. MAYOR ALFREDO S. LIM, HON. VICE MAYOR LITO ATIENZA, JR., SANGGUNIANG PANLUNGSOD NG MAYNILA, and CITY TREASURER ANTHONY Y. ACEBEDO and their agents or representatives, and HON. JUDGE JUAN C. NABONG, JR., Branch 32, Regional Trial Court of Manila, Respondents, WILLIAM LINES, INC., NEGROS NAVIGATION CO., INC., LORENZO SHIPPING CORPORATION, CARLOS A. GOTHONG LINES, INC., ABOITIZ SHIPPING CORPORATION, ABOITIZ AIR TRANSPORT CORPORATION, ABOITIZ HAULERS, INC., SOLID SHIPPING LINES CORPORATION and PNOC SHIPPING & TRANSPORT CORPORATION, Intervenors. G.R. Nos. 121847-55 COSCO CONTAINER LINES and HEUNG-A SHIPPING CO., LTD., both represented by their Resident Agent, Wallem Philippines Shipping, Inc.; DSR SENATOR LINES, COMPANIA SUD AMERICANA DE VAPORES S.A., and ARIMURA SANGYO COMPANY, LTD., all represented by their Resident Agent, C.F. Sharp Shipping Agencies, Incorporated; PACIFIC INTERNATIONAL LINES (PTE) LTD. and PACIFIC EAGLE LINES (PTE) LTD., both represented by their Resident Agent, TMS Ship Agencies, Inc.; COMPAGNIE MARITIME D’ AFFRETEMENT (CMA), represented by its Resident Agent, Inchcape Shipping Services; EVERETT ORIENT LINES, INC., represented by its Resident Agent, Everett Steamship Corporation; YANGMING MARINE TRANSPORT CORP., represented by its Resident Agent, Sky International, Inc.; NIPON YUSEN KAISHA, represented by its Resident Agent, Fil-Japan Shipping Corporation; HYUNDAI MERCHANT MARINE CO. LTD., represented by its Resident Agent, Citadel Lines; MALAYSIAN INTERNATIONAL SHIPPING CORPORATION BERHAD, represented by its Resident Agent, Royal Cargo Agencies, Inc.; BOLT ORIENT LINE, represented by its Resident Agent, FILSOV Shipping Company, Inc.; MITSUI-O.S.K. LINES, LTD., represented by its Resident Agent, Magsaysay Agencies, Inc.; PHILS., MICRONESIA & ORIENT NAVIGATION CO. (PMSO LINE), represented by its Resident Agent, Van Transport Company, Inc.; LLOYD TRIESTINO DI NAVIGAZIONE S.P.A.N. and COMPAGNIE GENERALE MARITIME, both represented by their Resident Agent, F.E. Zuellig (M), Inc.; and MADRIGAL-WAN HAI LINES, Petitioners, - versus - CITY OF MANILA, MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA, SANGGUNIANG PANLUNGSOD and City Treasurer ANTHONY Y. ACEBEDO, Respondents G.R. No. 122333 SULPICIO LINES, INC., Petitioner, - versus - REGIONAL TRIAL COURT OF MANILA, BRANCH 32, CITY OF MANILA MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA, SANGGUNIANG PANLUNGSOD and CITY TREASURER ANTHONY ACEVEDO, Respondents. G.R. No. 122335 ASSOCIATION OF INTERNATIONAL SHIPPING LINES, INC., in its own behalf and in representation of its Members, Petitioner, - versus - CITY OF MANILA, MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA, SANGGUNIANG PANLUNGSOD and CITY TREASURER ANTHONY ACEVEDO, Respondents G.R. No. 122349 DONGNAMA SHIPPING CO., LTD. and KYOWA SHIPPING LTD. herein represented by SKY INTERNATIONAL, INC., Petitioners, - versus - COURT OF APPEALS, CITY OF MANILA MAYOR ALFREDO LIM, VICE MAYOR LITO ATIENZA, CITY COUNCIL OF MANILA, and CITY TREASURER ANTHONY ACEVEDO, Respondents. G.R. No. 124855

G.R. No. 120051/G.R. No. 121613/G.R. No. 121675/G.R. No. 121704/G.R. Nos. 121720-28/G.R. Nos. 121847-55/G.R. No. 122333/G.R. No. 122335/G.R. No. 122349/G.R. No. 24855 | 2014-12-10

Republic of the Philippines
Supreme Court
Manila
 
En Banc
 
DECISION

LEONARDO-DE CASTRO, J.:
 
Before the Court are 10 consolidated Petitions, the issue at the court of which is the constitutionality and/or validity of Section 21(B) of Ordinance No. 7794 of the City of Manila, otherwise known as the Revenue Code of the City of Manila (Manila Revenue Code), as amended by Ordinance No. 7807.2
 
I
ANTECEDENT FACTS

The Manila Revenue Code was enacted on June 22, 1993 by the City Council of Manila and approved on June 29, 1993 by then Manila Mayor Alfredo S. Lim (Lim). Section 21(B) of said Code originally provided:

Section 21. Tax on...