SSS vs.

Bacolod City GR L-35726, 21 July 1982 Second Division, Escolin (J):

5 concur

Facts: The Social Security System (SSS) is a government agency created under RA
1161. In pursuance of its operations, SSS maintains a number of regional offices,
one of which is a 5-storey building occupying 4 parcels of land in Bacolod City. Said
building and lands were assessed for taxation. For failure to pay the realty taxes
thereon, the city levid upon said properties. SSS sought reconsideration on the
ground that SSS is a government-owned and -controlled corporation and is exempt
from payment of real estate taxes. Issue: Whether SSS property in Bacolod City is
tax-exempt. Held: The distinction whether the government-owned or controlled
corporation exercises ministrant or proprietory function is of no relevance as the
exemption does not relate to legal fees but on realty taxes. The Charter of Bacolod
City does not contain any qualification whatsoever in providing fro the exemption
from real estate taxes of lands and building owned by the Government/ It is
axiomatic that when public property is involved, exemption is the rule and taxation
is the exception. PD 24, amending the Social Security Act of 1954, has already
removed all doubts as to the exemption of the SS from taxation (Section 16).