Philippine Fisheries Development Authority v. Court of Appeals

Summary

The Supreme Court resolved whether the Philippine Fisheries Development Authority (PFDA) must pay real property taxes on the Iloilo Fishing Port Complex (IFPC) and whether the complex could be auctioned for tax delinquency. The Court classified PFDA as a government instrumentality rather than a government-owned or controlled corporation, applying the criteria established in the MIAA case. As an instrumentality, PFDA enjoys general tax exemption under Section 133(o) of the Local Government Code, except for portions leased to private entities under Section 234(a). The Court declared the reclaimed land and port facilities as property of public dominion under Article 420 of the Civil Code, making them non-alienable and exempt from execution or foreclosure. The decision voided all tax assessments except those on leased portions and prohibited the City of Iloilo from auctioning the IFPC to satisfy tax obligations, requiring alternative collection methods for any legitimate tax delinquency on leased areas.