REYES VS. ALMANZOR GR 43839-46 April 26, 1991 196 SCRA 322 Paras, J.

: FACTS: Petitioner are owners of parcels of land leased to tenants. RA 6359 was enacted prohibiting for one year an increase in monthly rentals of dwelling units and said Act also disallowed ejectment of lessees upon the expiration of the usual period of lease. City assessor of Manila assessed the value of petitioners property based on the schedule of market values duly reviewed by the Secretary of Finance. The revision entailed an increase to the tax rates and petitioners averred that the reassessment imposed upon them greatly exceeded the annual income derived from their properties. ISSUE: Whether or not income approach is the method to be used in the tax assessment and not the comparable sales approach. RULING: By no stretch of the imagination can the market value of properties covered by PD 20 be equated with the market value of properties not so covered. In the case at bar, not even factors determinant of the assessed value of subject properties under the comparable sales approach were presented by respondent namely: 1. That the sale must represent a bonafide arms length transaction between a willing seller and a willing buyer 2. The property must be comparable property. As a general rule, there were no takers so that there can be no reasonable basis for the conclusion that these properties are comparable. Taxes are lifeblood of government, however, such collection should be made in accordance with the law and therefore necessary to reconcile conflicting interests of the authorities so that the real purpose of taxation, promotion of the welfare of common good can be achieved.