COMMISSIONER OF I NTERNAL REVENUE V .CA (298 SCRA83) Facts: Young Mens Christian Association of the Philippines, Inc.

(YMCA), a non-stock, non-profit institution, which conducts various programs and activities that are beneficial to the public pursuant to its religious, educational, and charitable objectives, is contesting the tax assessment made upon it by the Commissioner of Internal Revenue, citing Article VI, Section 28, paragraph 3 of the 1987 Constitution. Issue : Whether or not YMCA is exempt from the payment of taxes. Ruling: NO.W hat is exempted by Article VI, Section 28, paragraph 3 of the 1987 Constitution is not the institution itself; the exemption pertains only to property taxes. Moreover, Section 27 of the National Internal Revenue Code expressly disallows the exemption claimed by YMCA, as it mandates that the income of exempt organizations from any of their properties, real or personal, be subject to the tax imposed by the same Code. Thus, YMCA is exempt from the payment of property tax, but not income tax on the rentals from its property. The bare allegation alone that it is a non-stock, non-profit educational institution is insufficient to justify its exemption from the payment of income tax.