MIAA vs CA Case Digest
Petitioner Manila International Airport Authority (MIAA) operates the Ninoy Aquino International Airport (NAIA) Complex in Parañaque City under Executive Order No. 903, otherwise known as the Revised Charter of the Manila International Airport Authority (“MIAA Charter”). Executive Order No. 903 was issued on 21 July 1983 by then President Ferdinand E. Marcos. Subsequently, Executive Order Nos. 9091 and 2982 amended the MIAA Charter.
As the operator of the international airport, MIAA administers the land, improvements and equipment within the NAIA Complex. The MIAA Charter transferred to MIAA approximately 600 hectares of land,3 including the runways and buildings (“Airport Lands and Buildings”) then under the Bureau of Air Transportation.4 The MIAA Charter further provides that no portion of the land transferred to MIAA shall be disposed of through sale or any other mode unless specifically approved by the President of the Philippines.
Facts
MIAA received Final Notices of Real Estate Tax Delinquency from the City of Parañaque for the taxable years 1992 to 2001. MIAA’s real estate tax delinquency has ballooned to Php 624, 506, 725.42. The Court of Appeals ruled in favor of the City of Parañaque saying that MIAA is a government-owned and controlled corporation and therefore not exempted from real estate tax.
Issue
Whether MIAA is a GOCC
Ruling
No.
MIAA is an instrumentality of the National Government and thus exempt from local taxation. Second, the real properties of MIAA are owned by the Republic of the Philippines and thus exempt from real estate tax.
Wherefore, We declare the Airport Lands and Buildings of the MIAA EXEMPT from the real estate tax.
MIAA vs CA Case Digest
