G.R. No. L-18784. April 30, 1964. THE CITY OF MANILA and THE CITY ASSESSOR OF MANILA, petitioners, vs. THE BOARD OF ASSESSMENT APPEALS and PABLO DAÑO, in his capacity as husband of Julita Aquino and JULITA AQUINO and THE COURT OF TAX APPEALS, respondents.
FACTS

The City Assessor of Manila reassessed a property owned by spouses Pablo Daño and Julita Aquino, increasing its valuation for real estate tax purposes from P20 to P30 per square meter, effective 1961. The taxpayer-spouses appealed this new assessment to the City Board of Assessment Appeals, which, in a decision dated March 28, 1961, disapproved the increased assessment. Consequently, the City of Manila and its City Assessor filed a petition with the Court of Tax Appeals (CTA) to review and reverse the Board’s decision, seeking affirmation of the City Assessor’s new valuation.
The City Board of Assessment Appeals moved to dismiss the petition, contending that the City Assessor lacked the legal personality to appeal the Board’s decision. The CTA, in a resolution dated June 26, 1961, granted the motion and dismissed the petition for review. This prompted the City of Manila and the City Assessor to file the present petition for review by certiorari before the Supreme Court.

ISSUE

The sole legal issue is whether the petitioners, the City of Manila and the City Assessor of Manila, are entitled to appeal to the Court of Tax Appeals from the decision of the City Board of Assessment Appeals.

RULING

The Supreme Court partially granted the petition. It upheld the CTA’s dismissal as to the City Assessor but reversed it as to the City of Manila, remanding the case for further proceedings.
Regarding the City Assessor, the Court affirmed the CTA’s resolution, citing its established jurisprudence in Ursal vs. Court of Tax Appeals. The legal logic is that the City Assessor, being the official who made the original assessment, is essentially the administrative officer whose valuation was reviewed and reversed by his own superior administrative body (the Board of Assessment Appeals). He is not a party “adversely affected” by the Board’s decision within the meaning of the law granting appeal rights; his role is ministerial in executing the Board’s final determination.
Conversely, the Court held that the City of Manila possesses the legal personality to appeal. The CTA erroneously relied on Collector of Customs vs. Court of Tax Appeals, which merely held that a Collector could not appeal a decision of his administrative superior—a distinct issue. The governing law is Section 11 of Republic Act No. 1125 , which allows “any person, association or corporation adversely affected” by the Board’s decision to appeal. The City of Manila qualifies as such an entity. Pursuant to its Revised Charter ( Republic Act No. 409 ), a specific portion (one-fourth) of all real estate tax collections is allocated exclusively for the support of public primary schools and school buildings. A reduction in the assessed valuation of property directly diminishes the tax revenue accruing to this specific city fund. Therefore, the City has a direct and substantial financial interest adversely affected by the Board’s decision, entitling it to seek judicial review. The resolution was set aside, and the case was remanded to the CTA for proceedings on the merits.