G.R. No.

163072 April 2, 2009

MANILA INTERNATIONAL AIRPORT AUTHORITY, Petitioner,

vs.
CITY OF PASAY, SANGGUNIANG PANGLUNGSOD NG PASAY, CITY MAYOR OF PASAY, CITY
TREASURER OF PASAY, and CITY ASSESSOR OF PASAY, Respondents.

Facts:
The case involves a dispute between the Manila International Airport Authority (MIAA) and the
City of Pasay over the real property tax on NAIA Pasay properties.
MIAA operates and administers the Ninoy Aquino International Airport (NAIA) Complex.
The City of Pasay issued notices of levy and warrants of levy for the NAIA Pasay properties due
to delinquent real property taxes.
MIAA filed a petition seeking to enjoin the City of Pasay from imposing real property taxes on
the NAIA Pasay properties.
The Court of Appeals dismissed the petition and upheld the power of the City of Pasay to impose
and collect realty taxes on the NAIA Pasay properties.
Issue:
Whether the NAIA Pasay properties of MIAA are exempt from real property tax.
Ruling:
The Court ruled in favor of MIAA and declared the NAIA Pasay properties exempt from real
property tax imposed by the City of Pasay, except for the portions that MIAA has leased to
private parties.
Ratio:
The Court held that MIAA is not a government-owned or controlled corporation but a
government instrumentality vested with corporate powers.
As a government instrumentality, MIAA is exempt from any kind of tax from local governments.
The Court considered the NAIA Pasay properties as properties of public dominion, which are
owned by the Republic and thus exempt from real estate tax.
However, the Court clarified that only the portions of the NAIA Pasay properties that are leased
to private parties are subject to real property tax by the City of Pasay.