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NPC vs. Province of Bulacan

NATIONAL POWER CORPORATION, PETITIONER, VS. PROVINCIAL GOVERNMENT OF BULACAN, GLORIA P. STA. MARIA, MUNICIPAL ASSESSOR OF NORZAGARAY, AND THE MUNICIPAL GOVERNMENT OF NORZAGARAY, BULACAN, RESPONDENTS.

G.R. No. 207140 | 2023-01-30

D E C I S I O N
 
LOPEZ, M., J.:
 
A claim for exemption from real property tax (RPT), whether full or partial, does not deal with the authority and power of the local assessor to impose the assessment or the local treasurer to collect the tax.[1] The issue of exemption that pertains to the reasonableness or correctness of the assessment is a question of fact that administrative agencies should resolve. Therefore, compliance with the "payment under protest" requirement in Section 252 (a)[2] of the Local Government Code (LGC)[3] is mandatory. Otherwise, the local treasurer will not act on the protest, and the...