January 11, 1951
Ponente: Tuason, J.
FACTS
The Manila Race Horse Trainers assailed the validity of Manila Ordinance No. 3065, which imposed license fees to stable owners based on the number of race horses kept, for being unconstitutional.
The petitioners argued that the ordinance was a tax on race horses as distinct from the stables, since the tax was based on the number of horses in the stable. They also alleged that the same ordinance was discriminatory and was essentially a form of class legislation.
RULING
It is plain from the text of the whole ordinance that the number of horses is used in the assessment purely as a method of fixing an equitable and practical distribution of the burden imposed by the measure.
It cannot be adjuged as discriminatory or inequitable because it is but fair and just that for a boarding stable where only one horse is maintained proportionately less amount should be exacted than for a stable where more horses are kept and from which greater income is derived.
Equity in taxation is generally conceived in terms of ability to pay in relation to the benefits received by the taxpayer and by the public from the business or property taxed.
