Manila International Airport Authority v. Court of Appeals

Summary

The Supreme Court En Banc resolved the fundamental question of whether the Manila International Airport Authority (MIAA) is exempt from real estate taxation by local governments. The City of Parañaque assessed MIAA P624.5 million in real estate taxes for 1992-2001 and threatened to auction the airport properties. The Court ruled that MIAA is a government instrumentality, not a government-owned or controlled corporation, because it lacks the capital stock structure required by the Administrative Code definition. As an instrumentality, MIAA is exempt from local taxation under Section 133(o) of the Local Government Code. Additionally, the Airport Lands and Buildings constitute properties of public dominion under Article 420 of the Civil Code, being 'ports constructed by the State' for public use, and are therefore owned by the Republic and exempt from real estate tax. The Court declared void all tax assessments and auction proceedings, establishing important precedent on the taxation immunity of government instrumentalities and the classification of public airport facilities as properties of public dominion outside the commerce of man.