BIR Ruling

October 22, 1973 Mr. Gilberto M. Duavit Suite 410, Ermita Center Bldg. Roxas Blvd., Manila S i r : This refers to your letter dated September 5, 1973 requesting information whether or not the Chinese Pagoda to be erected at T. Alonzo Corner Doroteo Jose and Kusang-loob Sts., Sta. Cruz, Manila, where the Ruby Tower Apartment crumbled during the earthquake on August 2, 1968, falls within the purview of the provisions of subsection (3), Section 17, Article VIII of the Constitution quoted as follows: cdta "Charitable institutions, churches, personages or convents appurtenant thereto, mosques, and non-profit cemeteries, and all lands, buildings, and improvements actually, directly, and exclusively used for religious or charitable purposes shall be exempt from taxation." The foregoing constitutional provision exempts charitable and religious institutions from the payment only of the property tax (Apostolic Prefect vs. City Treasurer of Baguio, 71 Phil. 547, Finance Journal, June 1973, p. 52) which is not within the jurisdiction of this Office. Accordingly, on even date, your query has been forwarded to the Department of Finance for appropriate action. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."