Philippine Fisheries Development Authority v. The Honorable Court of Appeals

Summary

PFDA challenged real property tax assessments by Navotas Municipality on the Navotas Fishing Port Complex, claiming exemption as a government instrumentality operating on public domain reclaimed land. The Municipality assessed P23,128,304.51 in taxes for 1981-1990 and threatened public auction. Lower courts ruled PFDA was liable for all taxes as owner of the complex since 1982. The Supreme Court reversed, holding that while PFDA is a government instrumentality generally exempt from real property tax, the exemption doesn't apply to portions leased to private entities. The Court recognized NFPC as public domain property that cannot be auctioned, limiting PFDA's liability to P62,841,947.79 for taxes on leased portions only. This case clarifies the tax liability scope of government instrumentalities operating public infrastructure with mixed public-private usage.