GR 190324; (June, 2018) (Digest)
G.R. No. 190324, June 6, 2018
PHILIPPINE PORTS AUTHORITY, Petitioner, vs. THE CITY OF DAVAO, ET AL., Respondents.
FACTS
The Philippine Ports Authority (PPA) received a real property tax assessment from the City of Davao for its Sasa Port properties. PPA appealed this assessment to the Local Board of Assessment Appeals (LBAA), which dismissed the appeal. PPA then elevated the case to the Central Board of Assessment Appeals (CBAA), which also denied the appeal. Consequently, PPA filed a Petition for Review with the Court of Tax Appeals (CTA) to challenge the tax liability.
While the CTA case was pending, the City of Davao posted a notice of sale and subsequently auctioned the subject properties for alleged delinquent taxes. PPA then filed a separate Petition for Prohibition with the Court of Appeals (CA), seeking to nullify the City’s tax assessment, auction, and sale of its properties, arguing these acts were without jurisdiction. The CA dismissed PPA’s petition. Meanwhile, the CTA rendered a Decision declaring PPA’s Sasa Port properties exempt from real estate tax and voiding all related assessments, which decision became final and executory.
ISSUE
Whether the Court of Appeals correctly dismissed PPA’s Petition for Prohibition.
RULING
Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed that the Court of Tax Appeals possesses exclusive jurisdiction to grant injunctive relief in tax cases pending before it. Republic Act No. 1125, as amended by Republic Act No. 9282, explicitly grants the CTA the authority to issue injunctions or restraining orders in cases within its exclusive appellate jurisdiction. Since PPA’s core dispute regarding its tax exemption and the validity of the assessments was already pending on appeal before the CTA, it was the CTA—not the Court of Appeals—that had the exclusive jurisdiction to entertain any plea to enjoin the coercive tax collection processes, including the levy and auction of the properties.
The filing of the prohibition case with the CA while the same substantive tax issue was pending before the CTA constituted forum shopping. PPA pursued two different judicial remedies in two different courts to obtain the same relief—a declaration of tax exemption and a stop to the collection efforts—which is precisely what the rule against forum shopping prohibits. The CTA’s subsequent final and executory decision, which granted PPA the primary relief it sought by declaring the properties exempt, rendered the CA petition moot and academic. Therefore, the CA committed no error in dismissing the petition.