Thursday, October 24, 2019

[CASE DIGEST] ALFREDO PATALINGHUG v. HON. COURT OF APPEALS, RICARDO CRIBILLO, MARTIN ARAPOL, CORAZON ALCASID, and PRIMITIVA SEDO (G.R. No. 104786)


January 27, 1994
 
FACTS:

·         In 1982, the Sangguniang Panlungsod of Davao City enacted Ordinance No. 363, or the Expanded Zoning Ordinance of Davao City. 

·         Under said ordinance, funeral parlors/memorial homes in an area designated as a commercial district must be built not less than 50 meters from any residential structure, church, and other institutional building. 

·         In 1987, Alfredo Patalinghug was able to secure an approval and certification of zoning compliance from the Zoning Administrator for the construction of his funeral parlor business within the AC-2 District, which the subject Ordinance had designated as a commercial district. 

·         Subsequently, residents in the area filed a complaint, arguing that the funeral parlor under construction was situated within a 50-meter radius from the Iglesia ni Kristo Chapel and several residential structures. 

·         After investigating the matter, the Sangguniang Panlungsod found the construction in violation of the subject Ordinance. It found that the nearest residential structure, owned by Wilfred G. Tepoot, was only 8 inches to the south and was separated by a mere concrete fence.

·         Despite the Sanggunian's findings, the construction proceeded anyway, prompting the residents to bring the matter to the court. 

·         After conducting its own ocular inspection, the RTC dismissed the complaint based on the following findings:

o   that the residential building mentioned by the residents and Iglesia ni Kristo chapel were 63.25 meters and 55.95 meters away, respectively from the funeral parlor.

o   although the building owned by a certain Mr. Tepoot was adjacent to the funeral parlor, and was only separated therefrom by a concrete fence, said residential building was being rented by a certain Mr. Asiaten who was using it to his laundry business with machinery thereon.

o   the complainants' suit was premature as they failed to exhaust the administrative remedies provided by Ordinance No. 363.

·         CA: Reversed the RTC ruling and annulled the building permit issued to Patalinghug. It ruled that although the residential structures and Iglesia ni Kristo were beyond the 50-meter residential radius prohibited by Ordinance 363, the construction of the funeral parlor was within the 50-meter radius measured from Tepoot's building. It further ruled that although said building was used by Mr. Tepoot's lessee for laundry business, it was a residential lot as reflected in the tax declaration, thus paving the way for the application of Ordinance No. 363.

·         Hence, the instant petition.

RULING:  

Petition granted.

Is Mr. Tepoot's building residential or commercial? – COMMERCIAL.

·         Although the general rule is that factual findings of the Court of Appeals are conclusive on the SC, this admits of exceptions as when the findings or conclusions of the Court of Appeals and the trial court are contrary to each other.

·         In the case at bar, the testimony of City Councilor Vergara would show that Mr. Tepoot's building was used for a dual purpose both as a dwelling and as a place where a laundry business was conducted. But while its commercial aspect has been established by the presence of machineries and laundry paraphernalia, its use as a residence, other than being declared for taxation purposes as such, was not fully substantiated.

·         A tax declaration is not conclusive of the nature of the property for zoning purposes. As applied in this case, Mr. Tepoot's property may have been declared as residential for real estate taxation purposes but it remained within a commercial zone. A discrepancy may thus exist in the determination of the nature of property for real estate taxation purposes vis-a-vis the determination of a property for zoning purposes.

·         To reiterate, a tax declaration does not bind a provincial/city assessor, for under the Real Estate Tax Code,  appraisal and assessment are based on the actual use irrespective of "any previous assessment or taxpayer's valuation thereon," which is based on a taxpayer's declaration. In fact, a piece of land declared by a taxpayer as residential may be assessed by the provincial or city assessor as commercial because its actual use is commercial.

·         The RTC's determination that Mr. Tepoot's building was commercial strengthened by the fact that the Sangguniang Panlungsod had previously declared the questioned area as commercial. As such, even if Tepoot's building was declared for taxation purposes as residential, once a local government has reclassified an area as commercial, that determination for zoning purposes must prevail.

Whether Patalinghug's funeral parlor construction was in violation of Ordinance No. 363. – NO.

·         Having ruled that the nearest residential structures and the Iglesia ni Kristo Chapel are all beyond 50 meters from the funeral parlor, and having ruled that the adjacent building of Mr. Tepoot is commercial and not residential, it becomes clear then that Patalinghug's funeral parlor is not in violation of the city's zoning ordinance. 

·         Complainants failed to present convincing arguments to substantiate their claim that Cabaguio Avenue, where the funeral parlor was constructed, was still a residential zone. Unquestionably, the operation of a funeral parlor constitutes a "commercial purpose," as gleaned from Ordinance No. 363.

·         The declaration of the said area as a commercial zone thru a municipal ordinance is an exercise of police power to promote the good order and general welfare of the people in the locality. Corollary thereto, the state, in order to promote the general welfare, may interfere with personal liberty, with property, and with business and occupations. 

·         Thus, persons may be subjected to certain kinds of restraints and burdens in order to secure the general welfare of the state and to this fundamental aim of government, the rights of the individual may be subordinated. The ordinance which regulates the location of funeral homes has been adopted as part of comprehensive zoning plans for the orderly development of the area covered thereunder.