Fels Energy v. The Province of Batangas

Summary

FELS Energy and National Power Corporation challenged real property tax assessments on power barges moored in Batangas, arguing the barges were personal property exempt from real property tax. The Supreme Court denied both petitions, ruling that the appeals were time-barred for failure to appeal directly to the Local Board of Assessment Appeals within the 60-day period required by law. Instead, petitioners improperly filed a motion for reconsideration with the Provincial Assessor, a remedy not sanctioned under the Local Government Code. The Court applied res judicata principles, finding the parties had already litigated the same issues in a prior case (G.R. No. 165113) where NPC represented FELS' interests. On the merits, the Court confirmed that power barges constitute real property subject to taxation as immovable property by destination under the Civil Code, being structures intended to remain at a fixed place. FELS could not claim tax exemption under Section 234(c) of the Local Government Code because it, not NPC, operated the barges. The decision emphasizes strict construction of tax exemptions and the importance of preserving local government revenue collection rights.