MANILA RACE HORSE TRAINERS ASSOCIATION, INC vs.

MANUEL DE LA FUENTE
G.R. No. L-2947
January 11, 1951
Facts:
Manila Race Horses Trainers Association, Inc., a non-stock corporation, alleged that they
are owners of boarding stables for race horses and that their rights as such are affected
by Ordinance No. 3065 of the City of Manila. They pleaded that said ordinance be
declared invalid as it is violative under the Constitution.
On appeal, it is upheld that the ordinance is a tax on race horses as distinct from
boarding stables.
Under Ordinance No. 3065, the tax is assessed not on the owners of the horses but on
the owners of the stables, as counsel admitted in their brief. It is ordinary that the
number of horses is used in the assessment purely as a method of fixing an equitable
and practical distribution of the burden imposed by the measure.
Issue:
Weather or not the Ordinance is constitutional and valid as has been enacted in
accordance with the powers of the Municipal Board granted by the Charter of the City of
Manila.
Held:
The Court did not believe that the Ordinance made arbitrary classification. There is
equality and uniformity in taxation if all articles or kinds of property of the same class are
taxed at the same rate. Thus, it was held that, the fact that some places of amusement
are not taxed while others are taxed, is not argument at all against the equality and
uniformity of tax imposition." In applying this to the case, there would be discrimination if
some boarding stables of the same class used for the same number of horses were not
taxed or were made to pay less or more than others.
SILVESTER M. PUNSALAN, ET AL., vs.
THE MUNICIPAL BOARD OF THE CITY OF MANILA, ET AL.
G.R. No. L-4817
May 26, 1954
Facts:
Ordinance No. 3398 of the City of Manila was enacted to impose a municipal occupation
tax on persons exercising various professions in the city pursuant to paragraph 1 of
Section 18 of the Revised Charter of the City of Manila. Various professionals filed a suit
to the Court of First Instance of Manila to annul the ordinance and the provision of the
Manila charter authorizing it and the refund of taxes collected under the ordinance but
paid under protest.
Issue:
Whether or not the Ordinance violates the Equal Protection Clause.
Held:
The Court held that the Ordinance does not violate the Equal Protection Clause.
The legislature may select what occupation shall be taxed, and in the exercise of that
discretion it may tax all, or it may select for taxation certain classes and leave the other
untaxed. Furthermore, a professional who has paid the occupation tax under the NIRC
Code should be allowed to practice in Manila even without paying the similar tax
imposed by Ordinance No. 3398. The City cannot give what said professional already has.

This would not say that the Ordinance is invalid, but that only one tax should be imposed
upon a practitioner in Manila.

CITY OF BAGUIO vs.

FORTUNATO DE LEON
G.R. No. L-24756
October 31, 1968
FACTS:
Fortunato de Leon, the defendant-appellant, assailed the lower court decision upholding
the validity of an ordinance of the City of Baguio imposing a license fee on any person,
entity or corporation doing business in the City. The ordinance sourced its authority from
RA No. 329, thereby amending the city charter empowering it to fix the license fee and
regulate businesses, trades and occupations as may be established or practiced in the
City. De Leon was assessed for P50 annual fee it being shown that he was engaged in
property rental and deriving income therefrom. He argued that it is ultra vires for there is
no statury authority which expressly grants the City of Baguio to levy such tax, and that
there it imposed double taxation, and violates the requirement of uniformity.
ISSUE: Weather or not the arguments of the defendant-appellant are reasonable.
HELD:
The arguments are not reasonable. The court emphasized that RA 329 was enacted
empowering the City Council not only to impose a license fee but to levy a tax for
purposes of revenue, thus the ordinance cannot be considered ultra vires for there is
more than ample statury authority for the enactment thereof.
In addition, an argument against double taxation may not be invoked where one tax is
imposed by the state and the other is imposed by the city, so that where, as here,
Congress has clearly expressed its intention, the statute must be sustained even though
double taxation results.
And finally, violation of uniformity is out of place it being widely recognized that there is
nothing inherently obnoxious in the requirement that license fees or taxes be exacted
with respect to the same occupation, calling or activity by both the state and the political
subdivisions thereof.
ANTERO M. SISON, JR., vs.
RUBEN B. ANCHETA
G.R. No. L-59431
July 25, 1984
Facts:
Sison, as taxpayer, alleged that the provision under Section 21 of the National Internal
Revenue Code of 1977 unduly discriminated against him by the imposition of higher
rates upon his income as a professional, that it amounts to class legislation, and that it
transgresses against the equal protection and due process clauses of the Constitution as
well as the rule requiring uniformity in taxation. The success of the challenge posed in
this suit for declaratory relief or prohibition proceeding on the validity of Section I of
Batas Pambansa Blg. 135 depends upon a showing of its constitutional infirmity.
Issue:
Whether BP 135 violates the due process and equal protection clauses, and the rule on
uniformity in taxation.

Held:
The court held that the petitioner has no cause of action for prohibition. While the tax
rates for compensation income are lower than those for net income, such circumstance
does not necessarily result in lower tax payments for this receiving compensation
income. There is a need for proof of such persuasive character as would lead to a
conclusion that there was a violation of the due process and equal protection clauses.
The presumption of validity must prevail. Equality and uniformity in taxation means that
all taxable articles or kinds of property of the same class shall be taxed at the same rate.
Where the differentiation conforms to the practical dictates of justice and equity, similar
to the standards of equal protection, it is not discriminatory within the meaning of the
clause and is therefore uniform.
JUAN LUNA SUBDIVISION, INC.vs.
M. SARMIENTO, ET AL.
G.R. No. L-3538
May 28, 1952
Facts:
Plaintiff-appellee Juan Luna Subdivision is a local corporation that issued a check to the
City Treasurer of Manila for amount to be applied to its land tax for the second semester
of 1941. The records of the City Treasurer do not show what was done with the check.
After WWII, the City Treasurer refused to refund the corporations deposit or apply it to
such future taxes as might be found due, while the Philippine Trust Corp., to which the
check was presented, was unwilling to reverse its debit entry against Juan Luna Subd.
Said amount is also subject of another disagreement between the corporation and the
City Treasure, with the corporation claiming that the whole amount of the check for the
taxes for the last semester of 1941 have been remitted by Commonwealth Act 703 of
1945.
Issue: Whether or not the provision allowing the remission covers taxes paid before the
enactment of Commonwealth Act 703 or taxes that were still unpaid.
Held:
The Court held that the law is clear in which it applies to taxes and penalties due and
payable. The remission of taxes due and payable to the exclusion of taxes already
collected does not constitute unfair discrimination. Each set of taxes is a class by itself,
and the law would be open to attack as class legislation only if all taxpayers belonging to
one class were not treated alike. To refund those taxes with restored currency would be
unduly enrich many of the payers at a greater expense to the people at large.
Association of Custom Brokers vs.
The Municipality Board of the City of Manila
GR L-4376
May 22, 1953
Facts:
The Association of Customs Brokers, which is composed of all brokers and public service
operators of motor vehicles in the City of Manila, challenged the validity of Ordinance No.
3379 of Manila on the grounds: 1) that while it levies a so-called property tax, it is in
reality a license tax which is beyond the power of the Manila Municipal Board; 2) that
said ordinance offends against the rule on uniformity of taxes; and 3) that it constitutes
double taxation.
Issue: Whether or not the Ordinance 3379 is contradictory on the rule on uniformity of
taxes as ordained by the Constitution.
Held:

The Court ruled that Ordinance 3379 is null and void. There is an inequality in the
ordinance that renders it offensive to the Constitution.
While the tax in the Ordinance refers to property tax and it is fixed ad valorem, it is
merely levied on all motor vehicles operating within Manila with the main purpose of
raising funds to be expended exclusively for the repair, maintenance and improvement of
the streets and bridges in said city. The ordinance imposes a license fee although under
the cloak of an ad valorem tax to circumvent the prohibition in the Motor Vehicle Law.
The distinction is necessary if he ordinance intends to burden with tax only those
registered in Manila as may be inferred from the word operating used therein.

Ormoc Sugar Company, Inc. vs.

Treasurer of Ormoc City
G.R. No. 23794
February 17, 1968
Facts:
On January 29, 1964, the Municipal Board of Ormoc City passed Ordinance No. 4 (1964),
imposing "on any and all productions of centrifugal sugar milled at the Ormoc Sugar
Company, Inc., in Ormoc City a municipal tax equivalent to one per centum (1%) per
export sale to the United States of America and other foreign countries." Payments for
said tax were made, under protest, by Ormoc Sugar Company, Inc. Ormoc Sugar
Company, Inc. filed a complaint against the City of Ormoc alleging that the ordinance is
unconstitutional for being violative of the equal protection clause and the rule of
uniformity of taxation.
Issue: Whether or not the equal protection clause and rule of uniformity of taxation were
infringed?
Held:
The Court reversed the decision appealed. The challenged ordinance is declared
unconstitutional because the Equal Protection clause and Rule of Uniformity of taxation
were violated. Equal protection clause applies only to persons or things identically
situated and do not bar a reasonable classification of the subject of legislation. A perusal
of the requisites shows that the questioned ordinance does not meet them, for it taxes
only centrifugal sugar produced and exported by the Ormoc Sugar Company, Inc. and
none other. The taxing ordinance should not be singular and exclusive as to exclude any
subsequently established sugar central for the coverage of the tax.
The defendants-appellees are hereby ordered to refund the P12,087.50 plaintiff-appellant
paid under protest.
Jose B. L.vs.
Pedro Almanzor
G.R. Nos. L-49839-46 April 26, 1991
FACTS:
J.B.L. Reyes, Edmundo and Milagros Reyes, petitioners, owned a parcel of land in Tondo
that are leased and occupied as dwelling units by tenants who were paying monthly
rentals of not exceeding P300. In 1971 the Rental Freezing Law was passed prohibiting
for one year from its effectivity, an increase in monthly rentals of dwelling units where
rentals do not exceed three hundred pesos (P300.00), so that the Reyeses were

precluded from raising the rents and from ejecting the tenants. In 1973, respondent City
Assessor of Manila re-classified and reassessed the value of the subject properties based
on the schedule of market values, which entailed an increase in the corresponding tax
rates prompting petitioners to file a Memorandum of Disagreement averring that the
reassessments made were "excessive, unwarranted, inequitable, confiscatory and
unconstitutional" considering that the taxes imposed upon them greatly exceeded the
annual income derived from their properties. They argued that the income approach
should have been used in determining the land values instead of the comparable sales
approach which the City Assessor adopted.
ISSUE: Weather or not the approach on tax assessment used by the City Assessor
reasonable?
HELD:
The Court granted the petition. The decisions of public respondents are reversed and set
aside and the respondents are ordered to make a new assessment by the income
approach method to guarantee a fairer and more realistic basis of computation.
It was held that the tax assessment used is reasonable. The law operates equally and
uniformly on all persons under similar circumstances or that all persons must be treated
in the same manner. Consequently, it stands to reason that petitioners who are burdened
by the government by its Rental Freezing Laws under the principle of social justice should
not now be penalized by the same government by the imposition of excessive taxes
petitioners can ill afford and eventually result in the forfeiture of their properties.