This case involves a dispute over whether the Manila International Airport Authority (MIAA) is exempt from real estate taxes on the land and buildings of Ninoy Aquino International Airport. The officers of Parañaque City levied and auctioned off MIAA's property for unpaid taxes. MIAA argued it was exempt as an instrumentality of the government. The Court ruled that MIAA is an instrumentality of the government, not a government-owned corporation, and the airport land and buildings are part of the public dominion utilized for public use and transportation, so they cannot be subject to levy or auction. The case was dismissed.
This case involves a dispute over whether the Manila International Airport Authority (MIAA) is exempt from real estate taxes on the land and buildings of Ninoy Aquino International Airport. The officers of Parañaque City levied and auctioned off MIAA's property for unpaid taxes. MIAA argued it was exempt as an instrumentality of the government. The Court ruled that MIAA is an instrumentality of the government, not a government-owned corporation, and the airport land and buildings are part of the public dominion utilized for public use and transportation, so they cannot be subject to levy or auction. The case was dismissed.
Original Title
Manila International Airport Authority vs Court of Appeals
This case involves a dispute over whether the Manila International Airport Authority (MIAA) is exempt from real estate taxes on the land and buildings of Ninoy Aquino International Airport. The officers of Parañaque City levied and auctioned off MIAA's property for unpaid taxes. MIAA argued it was exempt as an instrumentality of the government. The Court ruled that MIAA is an instrumentality of the government, not a government-owned corporation, and the airport land and buildings are part of the public dominion utilized for public use and transportation, so they cannot be subject to levy or auction. The case was dismissed.
This case involves a dispute over whether the Manila International Airport Authority (MIAA) is exempt from real estate taxes on the land and buildings of Ninoy Aquino International Airport. The officers of Parañaque City levied and auctioned off MIAA's property for unpaid taxes. MIAA argued it was exempt as an instrumentality of the government. The Court ruled that MIAA is an instrumentality of the government, not a government-owned corporation, and the airport land and buildings are part of the public dominion utilized for public use and transportation, so they cannot be subject to levy or auction. The case was dismissed.
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Manila International Airport Authority vs Court of Appeals
GR No. 155650,July 20, 2006, 495 SCRA 591
Facts: Manila International Airport Authority (MIAA) is the operator of the Ninoy Aquino International Airport located at Paraaque City. The Officers at Paraaque City sent notices to MIAA due to real estate tax delinquency. MIAA then settled some of the amount. When MIAA failed to settle the entire amount, the officers Paraaque City threatened to levy and subject to auction the land and buildings of MIAA which they did. MIAA sought for a Temporary Restraining Order from the CA but failed to do so within the 60 days reglementary period, so the petition was dismissed. MIAA then sought for the TRO but unfortunately the TRO was received by the Paraaque City officers 3 hours after the public auction. MIAA claims that although the charter provides that the title of the land and building are with MIAA still the ownership is with the Republic of the Philippines. MIAA also contends that it is an instrumentality of the government and as such exempted from real estate tax. That the land and buildings land, the officers of Paraaque City claim that MIAA is a government owned and controlled corporation therefore not exempted to real estate tax. ISSUES: Whether or not MIAA is an instrumentality of the government and not the government owned and controlled corporation and as such exempted from tax. Whether or not the land and buildings of MIAA are part of the public dominion and thus cannot be the subject of levy and auction sale. RULLINGS: Under the local government code, government owned and controlled corporations are not exempted from real estate tax. MIAA is not a government owned and controlled corporations, for to become one MIAA should either be a stock or non stock corporation. MIAA is not a non stock corporations for its capital is not divided into shares. It is not a non stock corporation since it has no members. MIAA is an instrumentality of the government vested with corporate powers and government functions. Under the civil code, property may either be under public dominion or private ownership.Those under public dominion are owned by the State and are utilitized for public use., public service and for the development of national wealth. The ports included in the public dominion pertain either to seaports or airports. When properties under public dominion cease to be for public use and services, they form part of the patrimonial property of the State. The court held that the land and buildings are part of the public dominion. Since the airport is devoted for public use, for the domestic and international travel and transportation. Even if MIAA charge fees, this is for the support for its operation and for regulation and does not change the character of the land and buildings of MIAA as part of public dominion. As part of public dominion the land and buildings of MIAA are outside the commerce of man. To subject them so levy and public auction
is contrary to public policy. Unless the President issues a proclamation widrawing
the airport land and buildings from public use, these properties remain to be of public dominion and are inalienable. As long as the land and buildings are for the public use the ownership is with the Republic of the Philippines. Case dismissed.