Herrera v Quezon City Board of Assessment
GR No L-15270, September 30, 1961
FACTS:
In 1952, the Director of the Bureau of Hospitals authorized Jose V. Herrera and Ester Ochangco Herrera to establish and operate the St. Catherine’s Hospital. In 1953, the Herreras sent a letter to the Quezon City Assessor requesting exemption from payment of real estate tax on the hospital, stating that the same was established for charitable and humanitarian purposes and not for commercial gain. The exemption was granted effective years 1953 to 1955. In 1955, however, the Assessor reclassified the properties from “exempt” to “taxable” effective 1956, as it was ascertained that out of the 32 beds in the hospital, 12 of which are for pay-patients. A school of midwifery is also operated within premises of the hospital.
ISSUE:
Whether St. Catherine’s is exempt from realty tax
RULING:
Yes. The admission of pay-patients does not detract from the charitable character of a hospital, if all its funds are devoted exclusively to the maintenance of the institution as a public charity.
The exemption extends to facilities which are incidental to and reasonably necessary for the accomplishment of said
purpose – a school for training nurses, a nurses’ home, etc.
FACTS:
In 1952, the Director of the Bureau of Hospitals authorized Jose V. Herrera and Ester Ochangco Herrera to establish and operate the St. Catherine’s Hospital. In 1953, the Herreras sent a letter to the Quezon City Assessor requesting exemption from payment of real estate tax on the hospital, stating that the same was established for charitable and humanitarian purposes and not for commercial gain. The exemption was granted effective years 1953 to 1955. In 1955, however, the Assessor reclassified the properties from “exempt” to “taxable” effective 1956, as it was ascertained that out of the 32 beds in the hospital, 12 of which are for pay-patients. A school of midwifery is also operated within premises of the hospital.
ISSUE:
Whether St. Catherine’s is exempt from realty tax
RULING:
Yes. The admission of pay-patients does not detract from the charitable character of a hospital, if all its funds are devoted exclusively to the maintenance of the institution as a public charity.
The exemption extends to facilities which are incidental to and reasonably necessary for the accomplishment of said
purpose – a school for training nurses, a nurses’ home, etc.
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