G.R. No. L-6407, March 16, 1911
FRANCISCA FERNANDEZ, ET AL. vs. R.M. SHEARER, Provincial Treasurer of Pampanga

FACTS

The plaintiffs owned lands in Pampanga and constructed steam-powered sugar mills on them. The provincial treasurer assessed these mills as improvements to the real estate and included them in the tax rolls. The plaintiffs paid the corresponding taxes for several years without protest. Subsequently, they filed an action seeking: (a) a declaration that the mills are not improvements to the real estate; (b) an injunction to stop further assessment and collection of taxes on the mills; and (c) a refund of the taxes already paid.

ISSUE

1. Whether the sugar mills constitute improvements to the real estate for tax assessment purposes.
2. Whether the plaintiffs are entitled to a refund of the taxes paid, considering their failure to follow the statutory protest procedures.

RULING

1. Yes, the mills are improvements. The Court ruled that the mills erected on the property for manufacturing sugar are clearly improvements under Section 54 of the Municipal Code, which requires the assessment of real estate and its improvements at their true value.
2. No, the plaintiffs are not entitled to a refund. The Court emphasized that the plaintiffs failed to avail themselves of the administrative remedies provided by law. Under Sections 56, 57, and 58 of the Municipal Code, taxpayers must first present their objections to the board of assessors and, if necessary, appeal to the board of tax appeals before resorting to judicial action. Moreover, Section 84 prohibits courts from entertaining suits assailing the validity of a tax unless the taxpayer has paid under protest. The plaintiffs neither protested nor followed the required procedures; they paid the taxes without objection. Consequently, their action could not be maintained. The judgment of the Court of First Instance dismissing the complaint was affirmed.