Facts: The main question in this case is: is the income derived from rentals of real property

owned by Young Mens Christian Associationof the Philippines (YMCA) established as a

welfare, educational and charitable non-profit corporation subject to income tax under the
NIRC and the Constitution? In 1980, YMCA earned an income of P676,829 from leasing out a
portion of its premises to small shopowners, like restaurants and canteen operators and
P44k form parking fees.

Issue: Is the rental income of the YMCA taxable?

Held: Yes. The exemption claimed by the YMCA is expressly disallowed by the very wording
of the last paragraph of then Sec. 27 of the NIRC; court is duty-bound to abide strictly by its
literal meaning and to refrain from resorting to any convoluted attempt at construction. The
said provision mandates that the income of exempt organizations (such as YMCA) from any
of their properties, real or personal, be subject to the tax imposed by the same Code. Private
respondent is exempt from the payment of property tax, but nitincome tax on rentals from
its property.