THE YOUNG MEN'S CHRISTIAN ASSOCIATION OF MANILA, vs.

THE COLLECTOR OF
INTERNAL REVENUE
FACTS:
The Young Men's Christian Association (YMCA) came to the Philippine with the army
of occupation in 1898. Thereupon the Young Men's Christian Association of Manila was
incorporated under the law of the Philippine Islands and received its character in June, 1907.
A site for the new building was selected on Calle Concepcion, Ermita.
The city of Manila, contending that the property is taxable, assessed it and levied a tax
thereon. It was paid under protest and this action begun to recover it on the ground that the
property was exempt from taxation under the charter of the city of Manila. The decision was
for the city and the association appealed.
The association claims exemption from taxation on the ground that it is a religious,
charitable and educational institution combined.
It is claimed, however, that the institution is run as a business in that it keeps a lodging and
boarding house.
ISSUE:
WON the building and grounds of the Young Men's Christian Association of Manila are
subject to taxation, under section 48 of the charter of the city of Manila.
HELD:
NO. The statute does not say that it must be devoted exclusively to any one of the
purposes therein mentioned. It may be a combination of two or three or more of those
purposes and still be entitled to exempt.
The YMCA of Manila cannot be said to be an institution used exclusively for religious
purposes, or an institution used exclusively for charitable purposes, or an institution devoted
exclusively to educational purposes; but it can be truthfully said that it is an institution used
exclusively for all three purposes, and that, as such, it is entitled to be exempted from
taxation.
It may be admitted that there are 64 persons occupying rooms in the main building
as lodgers or roomers and that they take their meals at the restaurant below. These facts,
however, are far from constituting a business in ordinary acceptation of the word.