G.R. No. 3433
Date: March 2, 1907

FACTS
Felipe Zamora sued the City of Manila to recover taxes he had paid for the years 1901‑1902 on property in Manila that he claimed had been assessed at an amount exceeding 150 % of the valuation prescribed by Act 581. Act 975 was enacted “to provide relief to persons who have paid, in the city of Manila, taxes upon land for the years 1901 and 1902 upon an excessive assessment.” The City argued that “land” in the title and body of the act refers only to the ground or soil, excluding buildings and other improvements, so the statute could not be used to recover taxes on over‑valued realty that includes structures.

ISSUE
What is the proper construction of the word “land” in Act 975: does it encompass only the bare soil (narrow meaning) or does it include the ground together with the buildings and improvements thereon (broad meaning)?

RULING
The Court held that “land” in Act 975 must be given its broad, liberal construction, meaning the ground together with the buildings and improvements thereon. The interpretation is supported by (1) the context of the statute as a remedial measure intended to refund taxes collected on “grossly excessive valuations,” (2) the inconsistent use of “land” and “real estate” in other Commission acts, which precludes a uniform restrictive rule, and (3) the Spanish text of the act, where “propiedad inmueble” clearly denotes real property inclusive of improvements. Consequently, the trial court’s judgment denying relief was reversed, and judgment was entered in favor of the plaintiff, Zamora.