FACTS
Bayantel is a legislative franchise holder with the authority to establish and operate radio stations for domestic telco, radiophone, broadcasting and telecasting. Under its charter, is exempt from paying real estate taxes.
However, this exemption was withdrawn upon the LGC’s taking effect on January 1, 1992. Not long thereafter, Congress passed RA 7633 amending Bayantel’s original franchise, restoring its exemption status. Despite this exemption, the Quezon City government still assessed Bayantel for real estate taxes, which the latter refused to pay.
RULING
The Supreme Court ruled in favor of Bayantel.
Bayantel’s franchise being national in character, the "exemption" thus granted under Section 14 of Rep. Act No. 3259 applies to all its real or personal properties found anywhere within the Philippine archipelago.
The grant of taxing powers to local government units under the Constitution and the LGC does not affect the power of Congress to grant exemptions to certain persons, pursuant to a declared national policy.
The legal effect of the constitutional grant to local governments simply means that in interpreting statutory provisions on municipal taxing powers, doubts must be resolved in favor of municipal corporations.
