Case Digest: Bagatsing v. Ramirez, 74 SCRA 306
Taxation | Purposes of Taxation The Municipal Board of Manila enacted Ordinance No. 7522 regulating public markets, prescribing stall rentals, and imposing penalties. The Federation of Manila Market Vendors challenged the ordinance, arguing it was invalid because it was not published as required by the Revised Charter of Manila (R.A. 409) , which mandated publication before enactment and after approval. The City of Manila contended that compliance with the Local Tax Code (P.D. 231) was sufficient, since it only required publication after approval. The trial court declared the ordinance null and void for non-compliance with the Charter’s publication requirement. Which law governs the publication of a Manila tax ordinance—the R evised City Charter of Manila (R.A. 409) requiring publication before and after enactment, or th e Local Tax Code (P.D. 231) requiring publication only after approval. Controlling law on publication: The City Charter is special as to territory but genera...