Government owned real property is exempt from real property tax (RPT) except when the beneficial use

of the real property is granted to a taxable person. The general rule is that any real property owned by
the Republic or its political subdivisions is exempt from the payment of RPT except when the beneficial
use of the real property was granted to a taxable person. Executive Order No. 596 categorizes
Metropolitan Waterworks and Sewerage System (MWSS) as a government instrumentality vested with
corporate powers. Republic Act No. 10149 or the GOCC Governance Act of 2011 adopted the same
categorization and explicitly lists MWSS as exempt from the payment of RPT. Thus, the real properties of
the MWSS is exempt from real properties taxes, except if the beneficial use of its properties has been
extended to a taxable person. (Metropolitan Waterworks and Sewerage System vs. The Local
Government of Quezon City, City Treasurer of Quezon City, City Assessor of Quezon City, Sangguniang
Panlungsod ng Quezon City and City Mayor of Quezon City, G.R. No. 194388, 07 November 2018)