Mactan Cebu International Airport Authority (MCIAA) vs. Hon. Ferdinand J.

Marcos
GR 120082, September 11, 1996

FACTS: MCIAA was created by virtue of RA 6958. Since the time of its creator, MCIAA enjoyed the privilege of exemption
from payment of realty taxes in accordance with sec. 14 of its charter. On October 11, 1994 however The treasurer of
Cebu city demanded payments for realty taxes on several parcels of lands belonging to the petitioners. MCIAA objected
to such demand for payment as baseless and unjustified, claiming in its favour Sec. 14 of R.A. 6958 which exempt it
from payment of realty taxes. Respondent refuse to cancel MCIAAs tax account, insisting that it is the GOCCs whose tax
exemption privilege has been withdrawn by virtue of Sec 193 and 234 of the LGC.
ISSUE: Whether or not the contention meritorious?
RULING: No. Sec 193 LGC prescribe the general rule that they are withdrawn upon the effectivity of the code except
those granted to local water districts, cooperative duly registered under R.A. 6938, non-stock, non-profit hospitals and
educational institutions, and unless otherwise provided in the LGC the latter provision called only refer to Sec 234 which
enumerate the properties exempt from real property tax but the last paragraph of sec 234 further qualifies the retention
of the exemption. Only to those enumerated therein. Thus, for petitioner to be exempt must show that the parcels of
land in question any of those enumerated in 234.