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System Plus Computer College v. Caloocan City Digest

Systems Plus Computer College sought property tax exemption for land it was renting from sister companies for use in its educational activities. The city government denied the exemption because the land was owned by the sister companies. After the sister companies donated the land to Systems Plus, the tax exemption request was again denied. Systems Plus filed a petition for mandamus. The Supreme Court ruled against Systems Plus, finding that (1) the tax exemption claim first requires proving the land is exclusively used for education, which Systems Plus did not sufficiently show; and (2) the proper process is to appeal the tax assessment decision through the local and central assessment appeal boards, not seek mandamus.

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312 views1 page

System Plus Computer College v. Caloocan City Digest

Systems Plus Computer College sought property tax exemption for land it was renting from sister companies for use in its educational activities. The city government denied the exemption because the land was owned by the sister companies. After the sister companies donated the land to Systems Plus, the tax exemption request was again denied. Systems Plus filed a petition for mandamus. The Supreme Court ruled against Systems Plus, finding that (1) the tax exemption claim first requires proving the land is exclusively used for education, which Systems Plus did not sufficiently show; and (2) the proper process is to appeal the tax assessment decision through the local and central assessment appeal boards, not seek mandamus.

Uploaded by

Marc Dave Alcarde
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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SYSTEMS PLUS COMPUTER COLLEGE OF CALOOCAN CITY, petitioner, vs.

LOCAL GOVERNMENT
OF
CALOOCAN CITY, MAMERTO MANAHAN, ATTY. NESTOR D. FRANCISCO, respondents.
Ponente: Corona, J.

Facts:
Systems Plus Computer College is a non-stock and non-profit educational institution. It enjoys
property tax exemption from the local government on its buildings but not on the parcels of
land which petitioner is renting for P5,000 monthly from its sister companies, Consolidated
Assembly, Inc. (Consolidated Assembly) and Pair Management and Development
Corporation (Pair Management). Petitioner requested respondent city government of Caloocan
to extendtax exemption to the parcels of land claiming that the same were being used actually,
directly and exclusively for educational purposes pursuant to Article VI, Section 28(3) of the
1987 Constitution and other applicable provisions of the Local Government Code. Such request
was denied because the owner of the parcel of land was not Systems Plus but Consolidated
Assembly and Pair Management. Thereafter, the sister companies entered into an agreement
where the land was donated to Systems Plus. They then informed the City Assessor
of the donation and sought a reconsideration of the first decision. The City Assessor again
denied the request, reasoning that the donation was a mere farce to evade the payment of
taxes; that revenue officers, in proper cases, may disregard the separate corporate entity where
it serves as a shield for tax evasion; the grant of exemption from taxation rests upon the theory
that an exemption will benefit the body of people, and not upon any idea of lessening the
burden of individual or corporate owners; there is no showing that the parcels of land are
actually, directly and exclusively used either for religious, charitable, or educational purposes.
Petitioner filed a Petition for mandamus with the RTC.

Issue:
Will mandamus lie to against public respondents?

Ruling:
No.
Petitioner argues that it is seeking to enforce, through the petition for mandamus, a clear legal
right under the Constitution (Article VI, Section 28 [3]) and the pertinent provisions of the Local
Government Code granting tax exemption on properties actually, directly and exclusively used
for educational purposes. But petitioner is taking an unwarranted shortcut. The argument
irrelevantly presumes the existence of the fact which it must first prove by competent and
sufficient evidence before the City Assessor. The Assessor shall determine the value of a
property, or proportion thereof subject to tax, including the discovery, listing, classification and
appraisal of properties. It must be stressed that the authority to receive evidence, as basis for
classification of properties for taxation, is legally vested on the respondent City Assessor whose
action is appealable to the Local Board of Assessment Appeals and the Central Board of
Assessment Appeals, if necessary

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