MIAA v. C. A.

, 435 SCRA 591

Facts
The Manila International Airport Authority (MIAA) operates Ninoy International
Airport in Paranaque City. Paranaque City officers filed notices to MIAA
regarding real estate tax default. MIAA failed to settle the total amount, thus
authorities from Paranaque City threatened to tax and auction MIAA's land and
buildings, which they did. MIAA sought a Temporary Restraining Order from
the CA, but failed to do so within the 60-day reglementary period, hence the
petition was dismissed. MIAA then petitioned the Supreme Court for a TRO a
day before the public auction; the TRO was granted, although it was received
by Paranaque City police three hours after the auction.
MIAA maintains that, while the charter states that the title to the land and
building is with MIAA, ownership remains with the Republic of the Philippines.
MIAA further claims that it is a government instrumentality and hence free
from real estate taxes. MIAA's land and buildings are public property and
cannot be levied or sold at auction. On the other hand, Paranaque City officials
contend that MIAA is a government-owned and controlled organisation and
hence not exempt from real estate taxes.

Issue
Whether or not the land and buildings of MIAA are part of the public dominion
and thus cannot be the subject of levy and auction sale.

Ruling
The court ruled that MIAA's land and buildings are public property. The airport
is open to the public for domestic and international travel and transportation.
Even if MIAA charges fees to support its operations and regulations, this does
not alter the character of MIAA's property and buildings as public dominion.
MIAA's property and buildings are not subject to commercial trade because
they are part of the public domain. It is against public policy to levy and sell
them at public auction. Unless the President publishes a proclamation
withdrawing the airport land and buildings from public usage, they remain
public property and are inalienable.