Philippine Fisheries Development Authority (Pfda) v. Central Board of Assessment Appeals

Summary

The Supreme Court ruled that the Philippine Fisheries Development Authority (PFDA) is exempt from paying real property tax on the Lucena Fishing Port Complex. The case arose when Lucena City assessed taxes totaling over P45 million for 1993-2000. Lower courts ruled PFDA liable, treating it as a government-owned corporation. However, the Supreme Court clarified that PFDA is a government instrumentality, not a corporation, and therefore exempt under Section 133(o) of the Local Government Code. Additionally, the fishing port complex constitutes property of public dominion under Civil Code Article 420, being a port constructed by the State for public use. The Court exempted the entire complex except portions leased to private entities, establishing important precedent on government instrumentality tax exemptions and public dominion property classification.