Phil. Press Institute, Inc. v.

Comelec
Facts: Petition for Certiorari and Prohibition with prayer for the issuance of a Temporary Restraining Order. PPI,
a non-stoc, non-profit organi!ation of newspaper and maga!ine pub"ishers, ass us to dec"are Come"ec
Reso"ution #o. $%%$ unconstitutiona" and &oid on the ground that it &io"ates the prohibition imposed by the
Constitution upon the go&ernment, and any of its agencies, against the taing of pri&ate property for pub"ic use
without 'ust compensation. Petitioner a"so contends that the $$ (arch )**+ "etter directi&es of Come"ec re,uiring
pub"ishers to gi&e free -Come"ec .pace- and at the same time process raw data to mae it camera-ready,
constitute impositions of in&o"untary ser&itude, contrary to the pro&isions of .ection )/ 0$1, 2rtic"e III of the )*/%
Constitution. Fina""y, PPI argues that .ection / of Come"ec Reso"ution #o. $%%$ is &io"ati&e of the constitutiona""y
guaranteed freedom of speech, of the press and of e3pression.
On the other hand, The Office of the .o"icitor 4enera" fi"ed its Comment on beha"f of respondent Come"ec
a""eging that Come"ec Reso"ution #o. $%%$ does not impose upon the pub"ishers any ob"igation to pro&ide free
print space in the newspapers as it does not pro&ide any crimina" or administrati&e sanction for non-comp"iance
with that Reso"ution. 2ccording to the .o"icitor 4enera", the ,uestioned Reso"ution mere"y estab"ished guide"ines
to be fo""owed in connection with the procurement of -Come"ec space,- the procedure for and mode of a""ocation
of such space to candidates and the conditions or re,uirements for the candidate5s uti"i!ation of the -Come"ec
space- procured. 2t the same time, howe&er, the .o"icitor 4enera" argues that e&en if the ,uestioned Reso"ution
and its imp"ementing "etter directi&es are &iewed as mandatory, the same wou"d ne&erthe"ess be &a"id as an
e3ercise of the po"ice power of the .tate. The .o"icitor 4enera" a"so maintains that .ection / of Reso"ution #o.
$%%$ is a permissib"e e3ercise of the power of super&ision or regu"ation of the Come"ec o&er the communication
and information operations of print media enterprises during the e"ection period to safeguard and ensure a fair,
impartia" and credib"e e"ection.
Issue: 6hether or not Reso"ution #o. $%%$ issued by respondent Commission on 7"ections is &a"id.
8e"d: Petition for Certiorari and Prohibition is 4R2#T79 in part and .ection $ of Reso"ution #o. $%%$ in its
present form and the re"ated "etter-directi&es dated $$ (arch )**+ are hereby .7T 2.I97 as nu"" and &oid, and
the Temporary Restraining Order is hereby (297 P7R(2#7#T. The Petition is 9I.(I..79 in part, to the
e3tent it re"ates to .ection / of Reso"ution #o. $%%$. #o pronouncement as to costs.
.ection $ of Reso"ution #o. $%%$, in its present form and as interpreted by Come"ec in its $$ (arch )**+ "etter
directi&es, purports to re,uire print media enterprises to -donate- free print space to Come"ec. 2s such, .ection $
suffers from a fata" constitutiona" &ice and must be set aside and nu""ified. To the e3tent it pertains to .ection / of
Reso"ution #o. $%%$, the Petition for Certiorari and Prohibition must be dismissed for "ac of an actua", 'usticiab"e
case or contro&ersy.
Association of Small Landowners vs Sec of Agrarian Reform
The sub'ects of this petition are a *-hectare rice"and wored by four tenants and owned by petitioner #ico"as
(anaay and his wife and a +-hectare rice"and wored by four tenants and owned by petitioner 2ugustin
8ermano, :r. The tenants were dec"ared fu"" owners of these "ands by 7.O. #o. $$/ as ,ua"ified farmers under
P.9. #o. $%.
The petitioners are ,uestioning P.9. #o. $% and 7.O. #os. $$/ and $$* on grounds inter a"ia of separation of
powers, due process, e,ua" protection and the constitutiona" "imitation that no pri&ate property sha"" be taen for
pub"ic use without 'ust compensation.
They contend that President 2,uino usurped "egis"ati&e power when she promu"gated 7.O. #o. $$/. The said
measure is in&a"id a"so for &io"ation of 2rtic"e ;III, .ection <, of the Constitution, for fai"ure to pro&ide for retention
"imits for sma"" "andowners. (oreo&er, it does not conform to 2rtic"e =I, .ection $+0<1 and the other re,uisites of
a &a"id appropriation.
7minent domain is an inherent power of the .tate that enab"es it to forcib"y ac,uire pri&ate "ands intended for
pub"ic use upon payment of 'ust compensation to the owner. Ob&ious"y, there is no need to e3propriate where
the owner is wi""ing to se"" under terms a"so acceptab"e to the purchaser, in which case an ordinary deed of sa"e
may be agreed upon by the parties. It is on"y where the owner is unwi""ing to se"", or cannot accept the price or
other conditions offered by the &endee, that the power of eminent domain wi"" come into p"ay to assert the
paramount authority of the .tate o&er the interests of the property owner. Pri&ate rights must then yie"d to the
irresistib"e demands of the pub"ic interest on the time-honored 'ustification, as in the case of the po"ice power,
that the we"fare of the peop"e is the supreme "aw.
COMMISSIONR O! IR "S CN#RAL L$%ON &R$' CORP
F2CT.:This is a petition for re&iew under Ru"e <+ of Ru"es of Court seeing the nu""ification
of C2 decision granting respondent>s c"aim for ta3 e,ua" to the amount of the $?@ that it
e3tended to senior citi!ens on the "atter>s purchases pursuant to .enior Citi!ens 2ct.
Respondent deducted the tota" amount of Php$)*,%%/ from its gross income for the
ta3ab"e year )**+ whereby respondent did not pay ta3 for that year reporting a net "oss of
Php$?,*AB in its corporate income ta3. In )**A, c"aiming that the Php$)*,%%/ shou"d be
app"ied as a ta3 credit, respondent c"aimed for refund in the amount of Php)+?, )*B.
I..C7:
6hether or not the $?@ discount granted by the respondent to ,ua"ified senior
citi!ens may be c"aimed as ta3 credit or as deduction from gross sa"esD
RCEI#4:
FTa3 creditG is e3p"icit"y pro&ided for in .ec< of R2 %<B$. The discount gi&en to
.enior citi!ens is a ta3 credit, not a deduction from the gross sa"es of the estab"ishment
concerned. The ta3 credit that is contemp"ated under this 2ct is a form of 'ust
compensation, not a remedy for ta3es that were erroneous"y or i""ega""y assessed and
co""ected. In the same &ein, prior payment of any ta3 "iabi"ity is a pre-condition before a
ta3ab"e entity can benefit from ta3 credit. The credit may be a&ai"ed of upon payment, if any. 6here there is no
ta3 "iabi"ity or where a pri&ate estab"ishment reports a net "oss for
the period, the ta3 credit can be a&ai"ed of and carried o&er to the ne3t ta3ab"e year.
(esus is Lord Christian School !oundation, Inc. v. Cit) of Pasig
Facts:
The (unicipa"ity of Pasig needed an access road from 7. R. .antos .treet, a municipa" road near the Pasig
Pub"ic (aret, to Harangay .to. Tomas Huid, Pasig, where A? to %? houses, most"y made of "ight materia"s,
were "ocated. The road had to be at "east three meters in width, as re,uired by the Fire Code, so that fire trucs
cou"d pass through in case of conf"agration. Eiewise, the residents in the area needed the road for water and
e"ectrica" out"ets. The municipa"ity then decided to ac,uire +) s,uare meters out of the ),%*)-s,uare meter
property of Eoren!o Ching Cuanco, =ictor Ching Cuanco and 7rnesto Ching Cuanco Iho co&ered by a transfer
certificate of tit"e which is abutting 7. R. .antos .treet.
On 2pri" )*, )**B, the .angguniang Hayan of Pasig appro&ed an Ordinance authori!ing the municipa" mayor to
initiate e3propriation proceedings to ac,uire the said property and appropriate the fund therefor. The ordinance
stated that the property owners were notified of the municipa"ity>s intent to purchase the property for pub"ic use
as an access road but they re'ected the offer.
On :u"y $), )**B, the municipa"ity fi"ed a comp"aint, amended on 2ugust A, )**B, against the Ching Cuancos for
the e3propriation of the property under .ection )* of Repub"ic 2ct 0R.2.1 #o. %)A?, otherwise nown as the Eoca"
4o&ernment Code. The p"aintiff a""eged therein that it notified the defendants, by "etter, of its intention to
construct an access road on a portion of the property but they refused to se"" the same portion. The p"aintiff
appended to the comp"aint a photocopy of the "etter addressed to defendant Eoren!o Ching Cuanco.
The respondent has demonstrated the necessity for constructing a road from 7. R. .antos .treet to .to. Tomas
Huid. The witnesses, who were residents of .to. Tomas Huid, testified that a"though there were other ways
through which one can enter the &icinity, no &ehic"e, howe&er, especia""y fire trucs, cou"d enter the area e3cept
through the new"y constructed 9amayan .treet. This is more than sufficient to estab"ish that there is a genuine
necessity for the construction of a road in the area. 2fter a"", abso"ute necessity is not re,uired, on"y reasonab"e
and practica" necessity wi"" suffice.
Issue:
6hether or not there was no due processD
8e"d:
Petition is granted. 8owe&er, as correct"y pointed out by the petitioner, there is no showing in the record that an
ocu"ar inspection was conducted during the tria". If, at a"", the tria" court conducted an ocu"ar inspection of the
sub'ect property during the tria", the petitioner was not notified thereof. The petitioner was, therefore, depri&ed of
its right to due process. It bears stressing that an ocu"ar inspection is part of the tria" as e&idence is thereby
recei&ed and the parties are entit"ed to be present at any stage of the tria".J%BK Conse,uent"y, where, as in this
case, the petitioner was not notified of any ocu"ar inspection of the property, any factua" finding of the court
based on the said inspection has no probati&e weight. The findings of the tria" court based on the conduct of the
ocu"ar inspection must, therefore, be re'ected.
*eirs of (uancho Ardona v. Re)es +,- SCRA ,,.
F: The Phi"ippine Tourism 2uthority sought the e3propriation of $/$ 8a of "and in Harangay (a"ubog and Habag
in Cebu City. upon deposit of an amount e,ui&a"ent to )?@ of the &a"ue of the property, the CFI authori!ed the
PT2 to tae immediate possession of the property. The charter of the PT2 authori!es it to ac,uire through
condemnation proceedings "ands for tourist !one de&e"opment of a sports comp"e3. The petitioners who are
occupants of the "ands, fi"ed a petition for certiorari in the .C. They contended that 0)1 the taing was not for
pub"ic useL 0$1 the "and was co&ered by the "and reform programL and 0B1 e3propriation wou"d impair the
ob"igation of contracts.
87E9: The concept of pub"ic use is not "imited to traditiona" purposes for the construction of roads, bridges, and
the "ie. The idea that -pub"ic use- means -use by the pub"ic- has been discarded. 2s "ong as the purpose of the
taing is pub"ic, then the power of eminent domain comes into p"ay. It is accurate to state then that at present
whate&er may be beneficia""y emp"oyed for the genera" we"fare satisfies the re,uirement of pub"ic use. The
petititioners ha&e not shown that the area being de&e"oped is "and reform area and that the affected persons
ha&e been gi&en emancipation patents and certificates of "and transfer. The contract c"ause has ne&er been
regarded as a barrier to the e3ercise of the po"ice power and "iewise eminent domain.
&idi/io arth Savers Multi/ur/ose Association et al vs &NR Sec lisea 'o0un et al
Po"ice Power M 7minent 9omain
In )*/%, Cory ro""ed out 7O $%* wNc empowered 97#R to stipu"ate with foreign companies when it comes to
either technica" or financia" "arge sca"e e3p"oration or mining. In )**+, Ramos signed into "aw R2 %*<$ or the
Phi"ippine (ining 2ct. In )**<, Ramos a"ready signed an FT22 with 2rimco (ining Co, an 2ustra"ian company.
The FT22 authori!ed 2(C 0"ater C2(C1 to e3p"ore B%,??? ha of "and in Ouirino and #. =i!caya inc"uding Hrgy
9idipio. 2fter the passage of the "aw, 97#R ro""ed out its imp"ementing RRs. 9idipio petitioned to ha&e the "aw
and the RR to be annu""ed as it is unconstitutiona" and it constitutes un"awfu" taing of property. In seeing to
nu""ify Rep. 2ct #o. %*<$ and its imp"ementing ru"es 92O *A-<? as unconstitutiona", petitioners set their sight on
.ection %A of Rep. 2ct #o. %*<$ and .ection )?% of 92O *A-<? which they c"aim a""ow the un"awfu" and un'ust
FtaingG of pri&ate property for pri&ate purpose in contradiction with .ection *, 2rtic"e III of the )*/% Constitution
mandating that pri&ate property sha"" not be taen e3cept for pub"ic use and the corresponding payment of 'ust
compensation. They assert that pub"ic respondent 97#R, through the (ining 2ct and its Imp"ementing Ru"es
and Regu"ations, cannot, on its own, permit entry into a pri&ate property and a""ow taing of "and without
payment of 'ust compensation.
Tra&ersing petitioners> assertion, pub"ic respondents argue that .ection %A is not a taing pro&ision but a &a"id
e3ercise of the po"ice power and by &irtue of which, the state may prescribe regu"ations to promote the hea"th,
mora"s, peace, education, good order, safety and genera" we"fare of the peop"e. This go&ernment regu"ation
in&o"&es the ad'ustment of rights for the pub"ic good and that this ad'ustment curtai"s some potentia" for the use
or economic e3p"oitation of pri&ate property. Pub"ic respondents conc"uded that Fto re,uire compensation in a""
such circumstances wou"d compe" the go&ernment to regu"ate by purchase.G
I..C7: 6hether or not R2 %*<$ and the 97#R RRs are &a"id.
87E9: The .C ru"ed against 9idipio. The .C noted the re,uisites of eminent domain. They areL
0)1 the e3propriator must enter a pri&ate propertyL
0$1 the entry must be for more than a momentary period.
0B1 the entry must be under warrant or co"or of "ega" authorityL
0<1 the property must be de&oted to pub"ic use or otherwise informa""y appropriated or in'urious"y affectedL
0+1 the uti"i!ation of the property for pub"ic use must be in such a way as to oust the owner and depri&e him of
beneficia" en'oyment of the property.
In the case at bar, 9idipio fai"ed to show that the "aw is in&a"id. Indeed there is taing in&o"&ed but it is not wNo
'ust compensation. .ec %A of R2 %*<$ pro&ides for 'ust compensation as we"" as section )?% of the 97#R RR.
To wit,
.ection %A. 333 Pro&ided, that any damage to the property of the surface owner, occupant, or concessionaire as
a conse,uence of such operations sha"" be proper"y compensated as may be pro&ided for in the imp"ementing
ru"es and regu"ations.
.ection )?%. Compensation of the .urface Owner and Occupant- 2ny damage done to the property of the
surface owners, occupant, or concessionaire thereof as a conse,uence of the mining operations or as a resu"t of
the construction or insta""ation of the infrastructure mentioned in )?< abo&e sha"" be proper"y and 'ust"y
compensated.
Further, mining is a pub"ic po"icy and the go&ernment can in&oe eminent domain to e3ercise entry, ac,uisition
and use of pri&ate "ands.
'erochi v. &O
F2CT.
R2 *)BA, otherwise nown as the 7"ectric Power Industry Reform 2ct of $??) 07PIR21, which sought to impose
a uni&ersa" charge on a"" end-users of e"ectricity for the purpose of funding #2POCOR>s pro'ects, was enacted
and too effect in $??).
Petitioners
contest
the constitutiona"ity of the 7PIR2, stating that the imposition of the uni&ersa" charge on a"" end-users is
oppressi&e and confiscatory and amounts to ta3ation without representation for not gi&ing the consumers a
chance to be heard and be represented.
I..C7
6N# the uni&ersa" charge is a
ta3.
87E9
#O. The assai"ed uni&ersa" charge is not a ta3, but an e3action in the e3ercise of the .tate>s po"ice power. That
pub"ic we"fare is promoted may be g"eaned from .ec. $ of the 7PIR2, which enumerates the po"icies of the .tate
regarding e"ectrification. (oreo&er, the .pecia" Trust Fund feature of the uni&ersa" charge reasonab"y ser&es and
assures the attainment and perpetuity of the purposes for which the uni&ersa" charge is imposed 0e.g. to ensure
the &iabi"ity of the country>s e"ectric power industry1, further boosting the position that the same is an e3action
primari"y in pursuit of the .tate>s po"ice ob'ecti&es
9OCTRI#7
If generation of re&enue is the primary purpose and regu"ation is mere"y incidenta", the imposition is a ta3L but if
regu"ation is the primary purpose, the fact that re&enue is incidenta""y raised does not mae the imposition a ta3.
The ta3ing power may be used as
an imp"ement of po"ice power.
The theory behind the e3ercise of the power to ta3 emanates from necessityL
without
ta3es, go&ernment cannot fu"fi"" its mandate of promoting the genera" we"fare and we""-being of the peop"e.
Manila International Air/ort Authorit) vs. Court of A//eals
Facts:
(I22 recei&ed Fina" #otices of Rea" 7state Ta3 9e"in,uency from the City of ParaPa,ue for the ta3ab"e years
)**$ to $??). (I22>s rea" estate ta3 de"in,uency was estimated at PA$< mi""ion.
The City of ParaPa,ue, through its City Treasurer, issued notices of "e&y and warrants of "e&y on the 2irport
Eands and Hui"dings. The (ayor of the City of ParaPa,ue threatened to se"" at pub"ic auction the 2irport Eands
and Hui"dings shou"d (I22 fai" to pay the rea" estate ta3 de"in,uency.
(I22 fi"ed with the Court of 2ppea"s an origina" petition for prohibition and in'unction, with prayer for pre"iminary
in'unction or temporary restraining order. The petition sought to restrain the City of ParaPa,ue from imposing
rea" estate ta3 on, "e&ying against, and auctioning for pub"ic sa"e the 2irport Eands and Hui"dings.
Parana,ue>s Contention: .ection )*B of the Eoca" 4o&ernment Code e3press"y withdrew the ta3 e3emption
pri&i"eges of Fgo&ernment-owned and-contro""ed corporationsG upon the effecti&ity of the Eoca" 4o&ernment
Code. Respondents a"so argue that a basic ru"e of statutory construction is that the e3press mention of one
person, thing, or act e3c"udes a"" others. 2n internationa" airport is not among the e3ceptions mentioned in
.ection )*B of the Eoca" 4o&ernment Code. Thus, respondents assert that (I22 cannot c"aim that the 2irport
Eands and Hui"dings are e3empt from rea" estate ta3.
(I22>s contention: 2irport Eands and Hui"dings are owned by the Repub"ic. The go&ernment cannot ta3 itse"f.
The reason for ta3 e3emption of pub"ic property is that its ta3ation wou"d not inure to any pub"ic ad&antage, since
in such a case the ta3 debtor is a"so the ta3 creditor.
Issue:
6O# 2irport Eands and Hui"dings of (I22 are e3empt from rea" estate ta3 under e3isting "awsD Qes. 7rgo, the
rea" estate ta3 assessments issued by the City of ParaPa,ue, and a"" proceedings taen pursuant to such
assessments, are &oid.
8e"d:
). (I22 is #ot a 4o&ernment-Owned or Contro""ed Corporation
(I22 is not a go&ernment-owned or contro""ed corporation but an instrumenta"ity of the #ationa" 4o&ernment
and thus e3empt from "oca" ta3ation.
(I22 is not a stoc corporation because it has no capita" stoc di&ided into shares. (I22 has no stocho"ders or
&oting shares.
(I22 is a"so not a non-stoc corporation because it has no members. 2 non-stoc corporation must ha&e
members.
(I22 is a go&ernment instrumenta"ity &ested with corporate powers to perform efficient"y its go&ernmenta"
functions. (I22 is "ie any other go&ernment instrumenta"ity, the on"y difference is that (I22 is &ested with
corporate powers.
6hen the "aw &ests in a go&ernment instrumenta"ity corporate powers, the instrumenta"ity does not become a
corporation. Cn"ess the go&ernment instrumenta"ity is organi!ed as a stoc or non-stoc corporation, it remains a
go&ernment instrumenta"ity e3ercising not on"y go&ernmenta" but a"so corporate powers. Thus, (I22 e3ercises
the go&ernmenta" powers of eminent domain, po"ice authority and the "e&ying of fees and charges. 2t the same
time, (I22 e3ercises Fa"" the powers of a corporation under the Corporation Eaw, insofar as these powers are
not inconsistent with the pro&isions of this 73ecuti&e Order.G
$. 2irport Eands and Hui"dings of (I22 are Owned by the Repub"ic
a. 2irport Eands and Hui"dings are of Pub"ic 9ominion
The 2irport Eands and Hui"dings of (I22 are property of pub"ic dominion and therefore owned by the .tate or the
Repub"ic of the Phi"ippines.
#o one can dispute that properties of pub"ic dominion mentioned in 2rtic"e <$? of the Ci&i" Code, "ie Froads,
cana"s, ri&ers, torrents, ports and bridges constructed by the .tate,G are owned by the .tate. The term FportsG
inc"udes seaports and airports. The (I22 2irport Eands and Hui"dings constitute a FportG constructed by the
.tate. Cnder 2rtic"e <$? of the Ci&i" Code, the (I22 2irport Eands and Hui"dings are properties of pub"ic
dominion and thus owned by the .tate or the Repub"ic of the Phi"ippines.
The 2irport Eands and Hui"dings are de&oted to pub"ic use because they are used by the pub"ic for internationa"
and domestic tra&e" and transportation. The fact that the (I22 co""ects termina" fees and other charges from the
pub"ic does not remo&e the character of the 2irport Eands and Hui"dings as properties for pub"ic use.
The charging of fees to the pub"ic does not determine the character of the property whether it is of pub"ic
dominion or not. 2rtic"e <$? of the Ci&i" Code defines property of pub"ic dominion as one Fintended for pub"ic
use.G The termina" fees (I22 charges to passengers, as we"" as the "anding fees (I22 charges to air"ines,
constitute the bu" of the income that maintains the operations of (I22. The co""ection of such fees does not
change the character of (I22 as an airport for pub"ic use. .uch fees are often termed user>s ta3. This means
ta3ing those among the pub"ic who actua""y use a pub"ic faci"ity instead of ta3ing a"" the pub"ic inc"uding those
who ne&er use the particu"ar pub"ic faci"ity.
b. 2irport Eands and Hui"dings are Outside the Commerce of (an
The Court has a"so ru"ed that property of pub"ic dominion, being outside the commerce of man, cannot be the
sub'ect of an auction sa"e.
Properties of pub"ic dominion, being for pub"ic use, are not sub'ect to "e&y, encumbrance or disposition through
pub"ic or pri&ate sa"e. 2ny encumbrance, "e&y on e3ecution or auction sa"e of any property of pub"ic dominion is
&oid for being contrary to pub"ic po"icy. 7ssentia" pub"ic ser&ices wi"" stop if properties of pub"ic dominion are
sub'ect to encumbrances, forec"osures and auction sa"e. This wi"" happen if the City of ParaPa,ue can forec"ose
and compe" the auction sa"e of the A??-hectare runway of the (I22 for non-payment of rea" estate ta3.
c. (I22 is a (ere Trustee of the Repub"ic
(I22 is mere"y ho"ding tit"e to the 2irport Eands and Hui"dings in trust for the Repub"ic. .ection </, Chapter )$,
Hoo I of the 2dministrati&e Code a""ows instrumenta"ities "ie (I22 to ho"d tit"e to rea" properties owned by the
Repub"ic. n (I22>s case, its status as a mere trustee of the 2irport Eands and Hui"dings is c"earer because e&en
its e3ecuti&e head cannot sign the deed of con&eyance on beha"f of the Repub"ic. On"y the President of the
Repub"ic can sign such deed of con&eyance.
d. Transfer to (I22 was (eant to Imp"ement a Reorgani!ation
The transfer of the 2irport Eands and Hui"dings from the Hureau of 2ir Transportation to (I22 was not meant to
transfer beneficia" ownership of these assets from the Repub"ic to (I22. The purpose was mere"y toreorgani!e a
di&ision in the Hureau of 2ir Transportation into a separate and autonomous body. The Repub"ic remains the
beneficia" owner of the 2irport Eands and Hui"dings. (I22 itse"f is owned so"e"y by the Repub"ic. #o party c"aims
any ownership rights o&er (I22>s assets ad&erse to the Repub"ic.
e. Rea" Property Owned by the Repub"ic is #ot Ta3ab"e
.ec $B< of the E4C pro&ides that rea" property owned by the Repub"ic of the Phi"ippines or any of its po"itica"
subdi&isions e3cept when the beneficia" use thereof has been granted, for consideration or otherwise, to a
ta3ab"e person fo""owing are e3empted from payment of the rea" property ta3.
8owe&er, portions of the 2irport Eands and Hui"dings that (I22 "eases to pri&ate entities are not e3empt from
rea" estate ta3. For e3amp"e, the "and area occupied by hangars that (I22 "eases to pri&ate corporations is
sub'ect to rea" estate ta3.