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Petition for declaratory relief as regards the validity of a municipal ordinance imposing a license tax on motor
vehicles operating in Manila.
1. The petitioners, (1) a group of brokers and public service operators of motor vehicles in Manila, and (2)
a member thereof, challenged the validity of Ordinance 3379 of Manila’s municipal board.
2. The ordinance, enacted on 24 March 1950, imposed a 1% ad valorem license tax under the guise of a
property tax on motor and other vehicles operating within Manila.
3. The tax was said to be used for the repair and maintenance of roads and bridges within the city.
4. The petitioners prayed for declaratory relief with respect to this ordinance. They contended that the
ordinance:
a. was not a property tax but a license tax, the imposition of which was proscribed by the Motor
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Vehicles Law (Act 3992 Section 70b ).
b. failed to observe uniformity in taxation
c. amounted to double taxation
5. The respondents claimed that it has a power to impose a property tax pursuant to Manila’s revised
charter (Sec 18p, RA 409)
6. The CFI held that the ordinance is valid. Petition dismissed.
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No further fees than those fixed in this Act shall be exacted or demanded…or for the operation of any motor vehicle…Provided
that nothing in this Act shall be construed to exempt any motro vehicle from the payment of any lawful and equitable insular, local
or municipal property tax imposed thereupon…
Note: There is no discussion on double taxation but it may be inferred from SC’s view on first issue.