Systems Plus Computer College of Caloocan City v. Local Government of Caloocan City
REITERATIONFacts
The Antecedents: Petitioner Systems Plus Computer College, a non-stock, non-profit educational institution, leased parcels of land from its sister companies, Consolidated Assembly, Inc. and Pair Management and Development Corporation, for which it paid monthly rentals. Petitioner sought tax exemption for these leased lands, claiming they were used for educational purposes. Procedural History: The City Assessor denied the request, stating the lands were owned by corporations deriving income from rentals, thus not exclusively used for educational purposes. Subsequently, the lease agreements were converted into donations of beneficial use, and petitioner again sought reconsideration. The City government denied the application, implying the arrangement was a scheme to evade real property taxes and asserting that the beneficial use donation did not sufficiently prove exclusive educational use. Petitioner then filed a petition for mandamus with the Regional Trial Court (RTC), which dismissed it for being premature and for failure to exhaust administrative remedies. The RTC's denial of the motion for reconsideration led to the instant petition for certiorari. The Petition: Petitioner filed a petition for certiorari before the Supreme Court, assailing the RTC's resolution dismissing its petition for mandamus, imputing grave abuse of discretion on the part of the trial court for ruling that mandamus did not lie and that petitioner failed to exhaust available administrative remedies.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion in dismissing the petition for mandamus. Whether mandamus lies against the City Assessor to compel the grant of tax exemption. Whether petitioner failed to exhaust available administrative remedies.
Ruling
The petition for certiorari is dismissed. The Regional Trial Court did not commit grave abuse of discretion in dismissing the petition for mandamus.
Ratio Decidendi
On the issue of whether the Regional Trial Court committed grave abuse of discretion in dismissing the petition for mandamus: The Supreme Court held that the RTC did not commit grave abuse of discretion. Mandamus is a writ that commands a tribunal, corporation, board, or person to perform an act that the law specifically enjoins as a duty, or to admit another to the use and enjoyment of a right or office, when there is no other plain, speedy, and adequate remedy. However, where administrative remedies are available, a petition for mandamus generally does not lie. The Court found that the petitioner failed to exhaust the administrative remedies provided by law, specifically the appeal to the Local Board of Assessment Appeals. On the issue of whether mandamus lies against the City Assessor to compel the grant of tax exemption: The Court ruled that mandamus does not lie against the City Assessor in the exercise of his function of assessing properties for taxation purposes. While the duty to conduct assessments is ministerial, the actual exercise of this function, which includes classification and appraisal, is necessarily discretionary. Mandamus cannot be availed of to direct the exercise of judgment or discretion in a particular way or to reverse an action already taken in the exercise of such discretion. The determination of whether the properties are actually, directly, and exclusively used for educational purposes involves an assessment that falls within the City Assessor's discretionary powers. On the issue of whether petitioner failed to exhaust available administrative remedies: The Court affirmed the RTC's finding that petitioner failed to exhaust administrative remedies. Under Section 226 of RA 7160 (Local Government Code of 1991), an owner dissatisfied with the action of the assessor may appeal to the Local Board of Assessment Appeals within sixty (60) days from receipt of the written notice of assessment. The Court clarified that the City Assessor's determination regarding the taxability of properties, including their classification and appraisal, falls under the definition of "assessment" as provided in Section 199(f) of the Local Government Code. Therefore, petitioner should have first pursued the appeal to the Local Board of Assessment Appeals before resorting to judicial action. The petitioner's attempt to bypass these administrative agencies, even on the pretext of raising a pure question of law, violated the doctrine of exhaustion of administrative remedies.
Main Doctrine
A petition for mandamus does not lie to compel the City Assessor to grant tax exemption when administrative remedies, such as appeal to the Local Board of Assessment Appeals, have not been exhausted. Furthermore, mandamus cannot be used to control the exercise of discretion by a public officer.