Case Summary (G.R. No.

144104)

Parties Involved and Key Details

 Petitioner: The Lung Center of the Philippines, a non-stock and non-profit entity
that owns a parcel of land in Quezon City and operates a hospital known as the
Lung Center of the Philippines.
 Respondent: The City Assessor of Quezon City.
 Dispute: Assessment of real property taxes on the Lung Center's land and
hospital building.
 Claim: The petitioner argues that it is a charitable institution and therefore
exempt from real property taxes.
 Relevant Law: Section 28(3), Article VI of the Constitution.

Assessment of Real Property Taxes

 The City Assessor of Quezon City assessed the land and hospital building for real
property taxes.
 The petitioner disputed the assessment, claiming that it is a charitable institution
and should be exempt from such taxes.
 The petitioner argues that it meets the criteria of being a charitable institution
under Section 28(3), Article VI of the Constitution.

Rulings by Local and Central Boards of Assessment Appeals

 The Local Board of Assessment Appeals of Quezon City and the Central Board of
Assessment Appeals of Quezon City ruled against the petitioner.
 They stated that the petitioner was not a charitable institution and that its real
properties were not actually, directly, and exclusively used for charitable
purposes.
 The Court of Appeals affirmed this decision.

Petition for Review in the Supreme Court

 The petitioner filed a petition for review in the Supreme Court, arguing that it is
indeed a charitable institution and should be exempt from real property taxes.
 The Supreme Court partially granted the petition, ruling that the petitioner is a
charitable institution within the context of the Constitution and the law.
 However, the Court held that the portions of the land and hospital building 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.