Villanueva vs City of Iloilo

G.R. No. L-26521; December 28, 1968

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Facts:
On September 30, 1946, the Municipal Board of Iloilo City enacted Ordinance 86 imposing license tax
fees upon
tenement houses. The validity of such ordinance was challenged by Villanueva, owner of four
tenement houses containing 34 apartments. The Supreme Court held the ordinance to be ultra views.
On January 15, 1960, however, the municipal board, believing that it acquired authority to enact an
ordinance of the same nature pursuant to the Local Autonomy Act, enacted Ordinance 11, Villanueva
assailed the ordinance anew.

Issue:
Whether or not Ordinance 11 violate the rule of uniformity of taxation.

Held:
No. The Court has ruled the tenement houses constitute a distinct class of property and that taxes are
uniform and equal when imposed upon all property of the same class or character within the taxing
authority.

The fact that the owners of the other classes of buildings in Iloilo are not imposed upon by the
ordinance, or that tenement taxes are imposed in other cities do not violate the rule of equality and
uniformity. The rule does not require that taxes for the same purpose should be imposed in different
territorial subdivisions at the same time. So long as the burden of tax falls equally and impartially
on all owners or operators of tenement houses similarly classified or situated, equality and
uniformity is accomplished. The presumption that tax statutes are intended to operate uniformly and
equally was not overthrown therein.