G.R. No. 192945.

September 5, 2012

PERLAS-BERNABE, J.

FACTS:

Camarines Sur III Electric Cooperative, Inc. (CASURECO), an electric cooperative organized under
Presidential Decree (PD) No. 269 and registered with the National Electrification Administration (NEA), is
engaged in the business of electric power distribution to various end-users and consumers within the
City of Iriga and the municipalities of Nabua, Bato, Baao, Buhi, Bula and Balatan of the Province of
Camarines Sur (or the Rinconada area).

Petitioner City of Iriga assessed CASURECO deficiency franchise tax and real property taxes covering the
periods 1998 to 2003 and 1995 to 2003, respectively. CASURECO refused to pay and argued that as an
electric cooperative provisionally registered with the Cooperative Development Authority (CDA), it is
exempt from the payment of local taxes.