GR 41213; (August, 1934) (Digest)
G.R. No. 41213 ; August 29, 1934
MANILA RAILROAD COMPANY, plaintiff-appellant, vs. ASUNCION MITCHEL VIUDA DE SY QUIA, ET AL., defendants-appellants.
FACTS
The Manila Railroad Company expropriated a parcel of land owned by the estate of Pedro Sy Quia. The company took possession in February 1918, and final indemnity was paid in February 1927 after a Supreme Court decision. From 1918 to 1926, the estate’s administratrix paid the real estate taxes on the property. The City of Manila sued to collect the unpaid tax for 1927 from both the administratrix and the Railroad Company. To prevent the attachment and sale of the expropriated property, the Railroad Company paid the 1927 tax under protest in 1931 and then sued the heirs to recover this payment. The heirs, in turn, filed a counterclaim to recover the taxes they paid from 1918 to 1926. The trial court absolved both parties from each other’s claims.
ISSUE
1. Is the Manila Railroad Company entitled to recover from the heirs the 1927 real estate tax it paid?
2. Are the heirs entitled to recover from the Manila Railroad Company the real estate taxes they paid from 1918 to 1926?
RULING
1. No. The Supreme Court held that the Manila Railroad Company could not recover the 1927 tax payment. Under Section 2493 of the Revised Administrative Code, the real estate tax for a given year becomes due and payable on specific dates (June 30 and January 1 of the following year for installments). The company became the absolute owner of the property in February 1927, before the tax payment became delinquent. Therefore, the obligation to pay the 1927 tax fell upon the new owner, the Railroad Company, and not upon the former owners who were not in default at the time of transfer.
2. No. The Supreme Court also held that the heirs could not recover the taxes paid from 1918 to 1926. During those years, the property still legally belonged to the estate, making the estate responsible for the taxes. Furthermore, the expropriation indemnity already included legal interest from the date the Railroad Company took possession (February 1918), which was deemed sufficient compensation for the deprivation of possession, including the tax burden during that period. The Court affirmed the trial court’s judgment absolving both parties.
AI Generated by Armztrong.