Chavez v Ongpin (1990)

Chavez v Ongpin
GR No 76778, June 6, 1990

FACTS:
Section 21 of Presidential Decree 464 provides that every 5 years starting calendar year 1978, there shall be a
provincial or city general revision of real property assessments. The general revision was completed in 1984.
On November 25, 1986, President Corazon Aquino issued EO 73 stating that beginning January 1, 1987, the 1984
assessments shall be the basis of real property taxes. Francisco Chavez, a taxpayer and landowner, questioned the
constitutionality of EO 74. He alleges that it will bring unreasonable increase in real property taxes.

ISSUE:
Is EO 73 constitutional?

RULING:
Yes. Without EO 73, the basis for collection of real property taxes will still be the 1978 revision of property values.
Certainly, to continue collecting real property taxes based on valuations arrived at several years ago, in disregard of
the increases in the value of real properties that have occurred since then is not in consonance with a sound tax
system.
Fiscal adequacy, which is one of the characteristics of a sound tax system, requires that sources of revenue must be
adequate to meet government expenditures and their variations. 
Posted by Victor Morvis 
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Labels: taxation