2. Should be uniform and equitable 3. Either the person or the property being taxed is within the jurisdiction of the taxing authority 4. Complies with the requirements of due process 5. Does not infringe any constitutional limitations Art. XII sec 11 No franchise for the operation of a public utility shall be granted except under the condition that such privilege shall be subject to amendment, alteration or repeal by Congress as and when the common good so requires. 2 requisite for ADE for educ insti: 1. School must be non-stock and non-profit 2. The income is actually, directly, and exclusively used for educational purposes. Nb: assets and revenues refers to income taxes. 3. Substantial evidence to support the foregoing ADE on real property tax exemptions ~Direct and immediate and actual application of the property itself to the purposes for which the insti is organized ~ not the use of income from the real property ~property taxes only. Exempt from RET are lands, buildings, and improvements actually, directly, and exclusively used for religious, charitable, or educational purposes.
(exclusive – possessed and enjoyed to the exclusion of others)