Case Digest: National Development Co. v. Cebu City, 215 SCRA 382
Facts: The President issued Proclamation No. 430 (1939) reserving a parcel of public land in Cebu City for warehousing purposes under the National Warehousing Corporation (later absorbed by the National Development Company, NDC). A warehouse was constructed on the reserved land, and beginning 1948, Cebu City assessed and collected real property taxes from NDC on both the land and warehouse. By 1970, NDC had paid over ₱100,000 in real estate taxes, mostly without protest. NDC later demanded a refund, claiming the land and warehouse were exempt from taxation because they belonged to the Republic. The trial court ruled in favor of NDC, ordering Cebu City to refund taxes paid on the reserved land and warehouse. Cebu City appealed, arguing that NDC was liable since it used the property for business purposes and had not properly protested the payments. Issue: Whether the reserved public land and the warehouse built thereon are exempt from real property tax, and whether NDC may recover taxes ...