ARTICLE VI, SEC.
26 o the law in question does not constitute
PHILCONSA V. GIMENEZ
FACTS:
 Issue is regarding the constitutionality of RA
no. 3836 insofar as the same allows retirement
gratuity and commutation of vacation and sick
leave to senators and representatives and to
the elective officials of both houses
 Phil. Constitution Assoc Inc – is a non-profit
civic org incorporated under the PH laws
 Philconsa instituted a petition for prelim
injunction to restrain the auditor general of the
PH and the disbursement of officers of
Congress from passing in audit vouchers and
from countersigning checks or treasury
warrants in pursuant of RA 3836
 They argued that RA 3836 is unconstitutional
and void with respect to the retirement of
members of Congress
 RA 3836: An act amending subsection ©,
Section 12 of CA no.186 as amended by RA 396
o Retirement is likewise allowed to a
member, regardless of age, who ahs
rendered at least 20 years of service.
Allowed to both houses.
 Proposed:
o Provisions of retirement of the
members is not expressed in the title of
the bill
o Provision on retirement gratuity is an
attempt to circumvent the consti ban
on increase of salaries
o It’s a selfish class legislation b/c it allows
members and officers of Congress to
retire after 12 years of service
o Provision on vacation and sick leave
commutable t the highest rate received
 Sol-Gen office said:
o grant of retirement or pension benefits
under RA no. 3836 to the officers
objected by petitioners do not
constitute forbidden compensation
o title of law in question complies with
sec. 21 art vi of the consti
class legislation
o the petitioner has no locus standi
ISSUE: Whether or not RA 3836 is unconstitutional and
void
HELD: Yes, it is.
 RA 3836 amending the first paragraph of sec
12© of CA no. 186 as amended, the retirement
benefits are granted to members of the govt
service insurance system who have rendered at
least 20 years of service. THIS PROVISION IS
RELATED AND GERMANE TO THE SUBJ OF CA
NO. 186. However, the succeeding paragraphs
of RA 3836 refers to members of Congress and
to elective officers thereof whoe are not
members of govt service insurance system. To
provide retirement benefits to them would
relate subject matter NOT GERMANE to CA no.
186
 It is the duty of the court to declare the void
statute invoking sec. 26(1) of art vi of the
Consti.
TIO V. VIDEOGRAM REGULATORY BOARD
FACTS:
 Valentin Tio filed a petition on behalf of
other videogram operators adversely
affected
 Tio assailed the constitutionality of PD no.
1987 entitled “An Act creating the
videogram regulatory board” with broad
powers to regulate and supervise the
videogram industry.
 A month after the promulgation of pd no.
1987, PD no. 1994 amended the nat’l
internal revenue code: video tapes – there
shall be collected on each video-tape
cassette , ready for playback, regardless of
length an annual tax of five pesos.
 Greater Manila Theaters Assoc, Integrated
Movie Producers et al. INTERVENED in the
case over Tio’s opposition that the
allegations that the intervention was
necessary for the complete protection of
their rights and their survival and very
existence
Julienne Therese V. Salvacion- Consti 1 - 1M 1
 ISSUE: Whether or not PD 1987 is
unconstitutional on the ground that the title
was vague
HELD: No, it is not.
 The Constitutional requirement provided in ISSUE: Whether or not RA 7354 is unconstitutional
Section. 26(1) of Article VI of the 1987
Constitution provides that “every bill shall TITLE
embrace only one subject which shall be
expressed in the title thereof.”
 PD 1987 sufficiently complied with if the
title be comprehensive enough to include
the general purpose it seeks to achieve and
if all the parts of the statute are related and
germane to the subject matter expressed in
the title or as long as they are not
inconsistent with or foreign to the general
subject or title
 The requirement is satisfied if all the parts
of the statute are related and are germane.
 An act having a single general subject,
indicated in the title, may contain any
number of provisions no matter how
diverse they may be so long as they are not
inconsistent with or foreign to the general
subject.
PHILIPPINE JUDGES ASSOC. V. PRADO
FACTS:
 This petition is about Sec. 35 of RA 7354 as
implemented by the Phil Postal Corp through
its circ no. 92-28.
 These measures withdraw the franking
privileges of the SC, CA, RTC,MTC,MuTC and
land reg commissions and its registers of deeds
 Petitioners are members of the lower courts
who feel that their functions as judges will be
prejudiced by the above-named measures
 Nat’l Land Reg Authroity has taken common
cause with them as its own activities.
 Assailed the constitutionality of RA 7354 on the
ff grounds:
o Its title embraces more than one
subject and does not express its
purposes
o It did not pass the required readins in
both houses of congress and printed
copies of the bill in its final form were
not distributed
o It is discriminatory and encroaches on
the independence of the Judiciary
HELD: No, it is constitutional.
 Purpose of one title: prevent log-rolling
legislation, prevent surprise or fraud upon the
legislature by means of provisions in bills of
which the title gives no intimation, and which
might therefore be overlooked and carelessly
and unintentionally adopted, to fairly apprise
the people
 RA 7354: An Act Creating the Phil Postal Corp,
Defining its powers, functions and
responsibilities, providing for regulation of the
industry and for other purposes connected
therewith.
 Objectives of the law enumerated in Sec.3 .
Sec. 35 proivdes the principal target, repealing
clause – all frankling priv authorized by law are
hereby repealed except those in CA no. 265, RA
69,180,1414,2087 abd 5059. The corp may
continue the franking privilege.
 The title of the bill is not required to be an
index to the body of the act or to be
comprehensive as to cover every nigle detail of
the measure
 If title fairly indicates the general subject, and
reasonably covers all provisions, is not
calculated to mislead the leg or the people,
there is sufficient compliance.
 Repeal is the effect and not the subject of the
statute
 The withdrawal of ranking priv is germane to
the accomplishment of the principal objective
of RA 7354. Which is the creation of a more
efficient and effective postal service system.
READINGS
 Petitioners maintain that 2nd par of sec. 35
covering the repeal of franking priv was not
included in the original version of senate bill
no. 720 or HB no. 4200.
 Sec. 26(2), Article VI, 1987 consti: no bill passed
by either house shall become a law unless it
Julienne Therese V. Salvacion- Consti 1 - 1M 2
 has passed three readings on sep days, printed
copies thereof in its final form have been dist
to its members 3 days before its passage xxx
 Petitioners invoked sec. 74 of rules of the HoR
requiring that amendment to any bill when the
house and the state shall have diff thereon may
be settled by a conf committee by both
chambers.
 Conference committee- compromising
differences, deal genereally with subject
matter or it may be limited to resolveing the
precise differences bet the two houses . bill
was enrolled with its certification by sen. Pres
neptali a Gonzales and speaker mitra.
 Under the doctrine of separation of powers,
the Court may not inquire beyond the
certificiation of the approval of a bill from the
presiding officers o f Congress.
 Court declines to look into the petitioner’s
charges.
ABAKADA V. ERMITA
FACTS:
 Law in dispute is RA 9337 ( an act amending
numerous sections of nat’l internal revenue
code of 1997) : consolidation of three
legislative bills namely
o House bill No. 3555 - first reading.
House committee on ways and means
approved the bill
o HB no. 3705 – subsitituted hb no. 3105.
The hb no. 3555 is its mother bill.
Certified by the pres.
o Senate Bill no. 1950 – substitution of
senate bill no.s 3555 and 3705
 Senate agreed to the request of the HOR for a
committee conference on the disagreeing
provisions of the proposed bills
 After compromise, recommended for approval
 Consolidated – RA no. 9337
GR no. 168056
 Abakada filed a petition for prohibition.
Questioned the constitutionality of certain
sections of RA no. 9337. 10% vat on sale of
goods and properties, 10% vat on importation
of goods, 10% vat on sale of services and use or
lease of properties
 President raised the vat to 12% - January 1,
2006
 Abakada argued that the law is
unconstitutional as it constitutes abandonment
by Congress of its exclusive authority to fix the
rate of the taxes
GR NO. 168207
 Pimentel filed a petition for certiorari
assailing the constitutionality of Sec 4,5,6 of
RA 9337
 Questioned the stand-by authority of the
Pres to increase the vat rate to 12% on the
ground that it amounts to an undue
delegation of leg power
 Contended that the increase in the VAT
rate to 12% contingent on any of the two
conditions being satisfied violates the due
process clause in Art. III
o 12& increase is ambiguous b/c it
does not state I f the rate would be
returned to the orig 10% if
conditions are no longer satisified
o rate is unfair and unreasonable as
the people are unsure of the
applicable vat rate from year to year
o the increase in the vat rate should
only based on fiscal adequacy
 they also contend that the inclusion of a
stand-by authority granted to the Pres by
the bicameral conference committes is a
violation of the “no-amendment rule”
upon last reading of a bill laid down in art.
Vi sec 26(2) of the Consti
GR NO. 168461
 A petition for prohibition was filed by
Assoc of Pilipinas Shell Dealers assailing
Sec. 8 – requiring that input tax on
depreciable goods shall be amortized
over a 60month period, imposing a 70%
limit on the amount of input tax to be
credited against the output tax. Sec 12-
authorizing theGovt or any of it
spolitical subdivisions to deduct a 5%
final withholding tax on gross payments
Julienne Therese V. Salvacion- Consti 1 - 1M 3
  They contend that these provisions are
unconstitutional for being arbitrary,
oppressive, excessive, and confiscatory.
 Premised on the constitutional right of
non-deprivation of life liberty and
property without due process of law.
 The contested sections impose
limitations on the amount of input tax
that may be claimed
 Input tax partakes the nature of a
property that may not be confiscated,
appropriated, or limited without due
process of law
GR NO. 168463
 Several members of HOR led by Chiz Escuero
filed this petition for certiorari on the
constitutionality o rA 9377
o Sections 4,5,6, of RA 9337 constitute an
undue delegation of leg poer, in
violation of art vi sec 28 of consti
o Bicameral conference committee acted
without jurisdiction in deleting the no
pass on provisions present in SB 1950
and HB 3705
o Insertion by Bicameral Conf Committee
on several sections violates art vi, sec
24(1) of the Consti which provides that
tariff bills originate exclusively from the
HOR
GR No. 168730
 Governor Garcia filed a petition for certiorari
alleging the unconstitutionality of the law on
the ground that the limitiation on the
creditable input tax in effect allows vat-reg
establishments to retain a portion of the taxes
they collect, thus violating the principle that tax
collection and revenue should be solely
allocated for public reasons and expenditures
RESPONDENT’S COMMENT
 Relying on the case of Tolentino v Sec of
Finance, the procedural issues raised by
petitioners (legality of bicameral proceedings,
exclusive origination of revenue measures nad
the poer of the senate) have already been
settled.
 Undue delegation – they contend that the law
is complete and leaves no discretion to the
Prsident but to increase the rate to 12% once
any of the two conditions arise
 They refute the argument that the increase to
12% as well ast the 70% limitation on the
creditable input tax etc is arbitrary oppressive
etc.
 RA 9377 is an achor of the gov’t’s fiscal reform
agenda.
 Reform in the value-added system of taxation
is the core revenue measure that will tilt the
balance towards a sustainable macroeconomic
environment for economic growth
ISSUE: Whether or not RA 9377 is unconstitutional
HELD: Yes, it is.
Procedural: Bicameral Conference Committee
 In the event that the House does not agree
with the Senate on the amendment to any
bill or joint resolution, the differences may
be sttled by the conf committees of both
chambers
 Meet within 10 days after the composition
 Creation of such committee is in response
to a problem where the two houses of
Congress find themselves in disagreement
over changes or amendments introduced
by the other house in a leg bill.
Procedural: Art. Vi. Sec. 26(2)
 The petitioners’ argument that the practice
where a bicameral conference committee is
allowed to add or delete provisions in the
HB or SB after these had passed three
readings is in effect a circumvention of the
“no amendment rule” FAILS TO CONVINCE
THE COURT TO DEVIATE FROM ITS RULING
FROM TOLENTINO
o Art VI Sec (2) must be construed as
referring only to bills introduced for
the first tim in iehter house of
Congress, not to the conference
committee report.
 Provision: No bill passed by either House
shall become a law unless it has passed
three readings on separate days, and
printed copies thereof in its final form have
Julienne Therese V. Salvacion- Consti 1 - 1M 4
 been dist. To its mebmers 3 days before its
passage, except when the pres. Certifies to
the necessityof its immediate enactment to
meet a public calamity or emergency. Upon
the last reading of a bill, no amendment
thereto shall be allowed and the vote
thereon shall be taken immediately
thereafter the yeas and nays in the journal.
 “No-amendment rule” refers only to the
procedure to be followed by each house of
congress with regard to bills initiated in
each of said respective houses, before said
bill is transmitted to the other house for its
concurrence or amendment
Procedural: Art. Vi. Sec. 24
 RA 9337 does not violate this provision
 Petitioners admitted that the HBs initiated the
move for amending provisions of the NIRC
dealing mainly with VAT
 To insist that a revenue statute, and not only
the bill which initiated the leg process
culminating in the enactment of the law , must
substantially be the same as the house bill
would be to deny the senate’s power not only
to concur with amendments but also to
propose amendments. – Tolentino case
ARTICLE VI, SEC. 27
BENGZON V. DRILON
FACTS:
 Petitioners are retired justices of the SC and CA
who are currently receiving monthly pensions
under RA No. 910 as amended by RA no. 1797
 They filed an instant petition on their own
behalf and in rep. of all other retired justices
 Respondents (drilon, carague, and cajucom) are
sued in their official capacities being officials
involved in the implementation of the release
of funds appropriated in the annual
appropriations law
 RA 910 was enacted to provide the retirement
pensions of justices of the SC and CA who have
rendered at least 20 years of service in both
judic and govt, having attained the age of 70
years old or who resign by reason of incapacity
to discharge the duties of the office. ; retired
justice shall receive during the residue of his
natural life the salary which he was receiving at
the time of his retirement or resignation
 Amendment: in case the salary is increased or
decreased, such salary shall be deemed to be
the salary or the retirement pension which a
Justice who as of June 12,1944 had ceased to
be such to accept another position in the gov’t
or who retired was receiving at the time of
cessation in office.
 PD 644: authorized adjustment of the pension
of the retired justices of the SC< CA, etc. to the
prevailing rates of the salaries.
 PD 1638: automatic readjustment of
retirement pension of officers and enlistment
men were restored.
 PD 1909: provided the automatic readjustment
of of the pensions of the members of AFP.
 Realizing the discrimination, Congress passed
RA 1797 and RA 3595
 HB 16297 and SB 740 – the legislature saw the
need to reenact RA 1797 and 3595 to restore
said retirement pensions and priv. of the
retired justies and members of the ConCom in
roder to assure those serving in SC CA ConCom
etc….
 President Aquino VETOED Hb 16297 b/c it
would erode the very foundation of the gov’t’s
collective effort to adhere faithfully to and
enforce strictly the policy on standardization of
compensation as articulated in RA 6758
 Government should not grant distinct priv to
select group of officials whose retirement
benefits under existing laws have already
enjoyed pref treatment over the vast majority
 Prior to this petition, Retired CA Justices filed a
letter/petition asking the Court for
readjustment of their monthly pensions in acc
with RA NO. 1797. They reasoned out that PD
644 repealing RA 1797 did not become a law as
there was no valid publication
 The president then vetoed portions of Sec.1
and the entire Sec. 4 of the Special Provisions
for the SC of the PH and the lower courts and
Julienne Therese V. Salvacion- Consti 1 - 1M 5
 Sec. 1 and entire Sec. 2 of the Special
Provisions for the CA.
 REASON: the resolution of this honorable corut
in AM no. 91-8-225-ca , the bill which provided
for the automatic increase in the retirement
pensions of the justices by reenacting RA 1797
and RA 3595
ISSUE: Whether or not the veto of the President is
valid
HELD: No it is not valid
 The act of the executive in vetoing the
particular provisions is an exercise of a
constitutionally vested power. However, this
is not absolute. There are limitations
 The power to disapprove any item or items in
an appropriate bill does not grant the authority
to veto a part of an item and to approve the
remaining portion of the same item. The
Constitution provides that only a particular
item or items may be vetoed. The power to
disapprove an item or items in an appropriate
bill does not grant the authority to veto a part
of an item and to approve the remaining
portion of the same.
 The president cannot set aside or reverse a
final and executor judgment of this Court
through the exercise of the veto power.
 The Executive has no authority to set aside and
overrule a decision of the SC.
 The president has no power to enact or amend
statutes promulgated by her predecessors
much less to repeal existing laws.
 Neither may the veto power of the President HELD:
be exercised as a means of repealing RA 1797.
This is arrogating unto the presidency leg
powers which are beyond its authority.
PHILCONSA V. ENRIQUEZ
FACTS:
 THE HB NO. 10900: GENERAL APPROPRIATION
BILL OF 1994 was passed and approved by both
houses
 It imposed conditions and limitations on
certain items of appropriations in the proposed
budget submitted by the Pres.
 Authorized members of Congress to propose
and identify projects in the pork barrels
allotted to them and to realign their respective
operating budget.
 On the same day, the president delivered his
presidential veto message, specifying
provisions of the bill he vetoed and on which
he imposed certain conditions. No step was
taken in either house to override vetoes.
 Gr no. 113105 : Pihlconsa prayed that it be
declared unconstitutional and void
 GR no. 113174: 16 members of the senate
sought the issueance of the writs of certiorari
prohibition and mandamus ; questioned the
constitutionality of the conditions imposed by
the president , and constitutionality of the veto
of the special provisions in the appropriation
for debt service.
 Gr no. 113766: Romulo and Tanada sought writ
of prohibition and mandamus against exec sec ,
coa, etc. Seud as members of the senate and
taxpayers. Challenged the constitutionality of
the presidential veto of the special provision
in the appropriations for debt service and the
automati approp funds therefor.
 GR No. 113888 : Tanada and Romulo sought
writ of prohib and mandamus contesting the
constitutionality of the veto on four special
provisions, and the conditions imposed by the
pres in the implementation of certain
appropriations
ISSUE: Whether or not the president’s veto is valid
 A member of the Congress has the legal
standing to question the validity of a
presidential veto or any other act of the
Executive which injures the institution of
Congress
 An issue of impermissible intrusion of executive
into the domain of the legislature arises.
 An act of the Executive which injures the
institution of Congress causes a derivative but
nonetheless substantial injury, which can be
questioned by a member of Congress
 While the constitution provides a mechanism
for overrideing a veto, said remedy is only
Julienne Therese V. Salvacion- Consti 1 - 1M 6
 available when the presidential veto is based
on policy or political considerations, not when
the same I claimed to be ultra vires.
 IT becomes the duty of the Court to draw the issue EO 273 and won EO 273 is constitutional
dividing line where the exercise of executive
power ends and the bounds of legislative
jurisdiction begin.
 ANNULMENT OF THE VETO:
o Special provision on debt service
o 2 par of special provision no. 2 of the
nd
item of appropriation for the DPWH
o special prov no. 12 on the purchase of
medicines by AFP
ART. VI, SEC 28
KAPATIRAN NG MGA NAGLILINGKOD V. TAN
FACTS:
 Petitioners seek to nullify EO 273 issued by the
Pres. Of the Philippines that amended certain
sections of the NIRC and adopted VAT, for
being unconstitutional in that its enactment is
not allegedly within the powers of the
President.
 They contest that vat is oppressive,
discriminatory, regressive, and violates the due
process and equal protection clauses and other
provisions of the 1987 constitution
 SolGen prays for the dismissal of the petitions
on the ground that petitioners have failed to
show justification for the exercise of the
judicial powers
 Objections to taxpers’ suit for ack of sufficient
personality standing or interest are in the main
procedural matters
 VAT is a tax levied on a wide range of goods
and services; a tax on the value, added by
every seller with aggregate gross annual sales
and/or services exceeding P200000 to his
purchase of goods and services unless exempt
 VAT eliminated priv taxes, multiple rated sales
tax, advance sales tax and compensating tax.
 Framers of EO 273 claim that it is principally
aimed to rationalize the system of taxing goods
and services.
 Vat was already in force but just modified.
 Petitioners contend that the President had no
authority to issue EO 273.
ISSUE: Whether or not the President had authority to
HELD: Yes, she as authority and yes constitutional
 Under Proc. No. 3 : President had sole
legislative authority until a legislature is elected
and convened under a new Constitution
 1987 Consti: The incumbment president shall
continue to exercise legislative powers until the
first congress is convened.
 Convene = call together, cause to assemble or
convoke
 1987 Constitution mentions a specific date
when the President loses her power to legislate
 on being oppressive, unjust, discriminatory: Art
VI, Sec 28(1) – the rule of taxation shall be
uniform and equitable. The Congress shall
evolve a progressive system of taxation
 EO 273 satisfies all the requirements of a valid
tax
 A tax is considered uniform when it operates
with the same force and effect in every place
where the subject may be found.
 The sales tax adopted in EO 273 is applied
similarly on all goods and services sold to the
public, which are not exempt at a constant rate
of 0% to 12%.
 Disputed sales tax is also equitable. Imposed
only on sales of goods or services by persons
engage in the business with an aggregate gross
annual sales exceeding 200,000.
LUNG CENTER OF THE PH V. QUEZON CITY
FACTS:
 Phil. Lung Center of the PH is a non-stock
and non-profit entity established by PD
1823.
 It is the registered owner of a lot in QC.
 Erected there is a hospital known as the
Lung Center of the PH. A big space at the
ground floor is being leased to private
parties, canteen, small store spaces etc.
 ½ of the entire area on the left side of th
bldg. is vacant and idle
Julienne Therese V. Salvacion- Consti 1 - 1M 7
  Petitioner accepts paying and non-paying
patients. Renders med services to out-
patients, both paying and non-paying.
 City assessor of QC assessed the real
property taxes of petitioner worth
4,554,860 pesos.
 Petitioner filed a claim for exemption from
real property taxes. Request was denied.
 Petitioners invoked Sec 28, art VI, of the
1987 Constitution.
 Petitioner avers that it is a charitable
institution within the context of the
provision. They assert that its character as a
charitable institution is not altered by the
fact that it admits paying patients.
 It contends that the exclusivity required in
the Constitution does not necessarily mean
solely.
ISSUE: Whether or not the Lung Center of the PH is a
charitable institution within the context of PD 1823
and the Constitution and are exempt from real
property tax
HELD: Yes, they are a charitable institution. But not
fully exempt from tax
First issue:
 The SC held that petitioner is a charitable
institution within the context of the
Constitutions.
 To determine whether an enterprise is a
charitable institution : the elements are
corporate purposes, constitution and by-laws,
methods of admin, nature of actual work
performed, character of the services rendered,
indefiniteness of the beneficiaries and the use
and occupation of the properties
 Charity – may be fully defined as a gift to be
applied consistently with existing laws for the
benefit of an indefinite number of persons.
 It may be applied to almost anything that tend
to promote the well-doing and well-being of
social man.
 Charitable- not restricted to the poor and sick ISSUE: Whether or not the lot and building in question
 PD 1823: nonprofit, nonstick corp administered are used exclusively for educational purposes
by the office of the pres with ministry of health HELD: No, not exclusive. First floor is being used for
and human settlements.
Second issue:
 SC ruled that petitioner is indeed a charitable
institution but those portions of its real
property that are leased to private entities are
not exempt from real property taxes as they
are not actually, directly and exclusively used
for charitable purposes.
 Tax exemption from payment of taxes, charges,
fees, imposed by gov’t or any political
subdivision or instrumentality with respect to
equipment purchases made by lung center (PD
1823)
 Tax exemption in constitutionalprovision
covers property taxes only. RA 7160
implemetned the tax exemption : as long as
they are actually directly and exclusively used
for religious, charitable, or educational
purposes.
ABRA VALLEY COLLEGE INC V. AQUINO
FACTS:
 Abra Valley college is an educational corp and
institution of higher learning duly incorp with
SEC filed to annul and declare void the “notice
of seizure” and “the notice of sale” of its lot
and building for non-payment of real estate
taxes amounting to 5140.31 pesos
 Municipal mayor Paterno Millare offered the
highest bid that was accepted
 Parties entered into a stipulation of facts
adopted and embodied by the trial court in its
questioned decision
 Trial court also found that the school is
recognized by the government, located in the
heart of Bangued, elementary pupils are
housed in two-storey buildings across the
street , high school and college students are
housed in the main building, director with his
family is in the 2nd floor of the bldg., annual
gross income reaches more than 100000 pesos
 First floor was leased to the Northern
Marketing Corportaion.
commercial purposes. half of the assessed tax be
returned to the petitioner.
Julienne Therese V. Salvacion- Consti 1 - 1M 8
 Invoked Sec. 28(3) of the 1987 constitution
 As held in YMCA of MNL v CIR – the keeping of
a lodging and a boarding house and a resto for
its members do not constitute business in the
ordinary acceptance of the word .
 The exemption in favor of property used
exlusively for chartiable or educational
purposes is not limited to property actually
indispensable therefor but extends to facilities
which are incidental to and reasonably
necessary for the accomplishment of said
purposes.
 The exemption extends to facilities which are
incidental to and reasonably necessary for the
accomplishment of the main purpose.
 However, the Court finds that the first floor of
the school building should be taxed because it
was used for commercial purposes.

Julienne Therese V. Salvacion- Consti 1 - 1M 9