Villanueva v City of Iloilo (1968)

Villanueva v City v Iloilo

GR No L-26521, December 28, 1968

FACTS:
On September 30, 1946, the Municipal Board of Iloilo City enacted Ordinance 86
imposing license tax fees upon
tenement houses. The validity of such ordinance was challenged by Eusebio and
Remedios Villanueva, owners of four tenement houses containing 34 apartments.
The Supreme Court held the ordinance to be ultra views. On January 15, 1960,
however, the municipal board, believing that it acquired authority to enact an
ordinance of the same nature pursuant to the Local Autonomy Act, enacted
Ordinance 11, Eusebio and Remedios Villanueva assailed the ordinance anew.

ISSUE:
Does Ordinance 11 violate the rule of uniformity of taxation?

RULING:
No. The Court has ruled the tenement houses constitute a distinct class of property
and that taxes are uniform and equal when imposed upon all property of the same
class or character within the taxing authority.
The fact that the owners of the other classes of buildings in Iloilo are not imposed
upon by the ordinance, or that tenement taxes are imposed in other cities do not
violate the rule of equality and uniformity. The rule does not require that taxes for
the same purpose should be imposed in different territorial subdivisions at the
same time. So long as the burden of tax falls equally and impartially on all owners
or operators of tenement houses similarly classified or situated, equality and
uniformity is accomplished. The presumption that tax statutes are intended to
operate uniformly and equally was not overthrown therein.