Messrs. Arturo de Ocampo, Joel Sencida, Sr.,

March 19, 2009 BIR RULING [DA-(DT-015) 161-09] 101 (A) (3); S30-056-2001 Messrs. Arturo de Ocampo, Joel Sencida, Sr., Hernan Maguale, Felomino Blanco, Sr., Ismael Balceda and Arturo Gelisanga, Sr. Bantayan, Kabankalan Negros Occidental Sir : This refers to your letter dated August 20, 2007, as indorsed by the Regional Director, Revenue Region No. 12, Bacolod City, requesting for exemption from donor's tax relative to your donation of several properties to Iglesia ni Cristo. It appears that Messrs. Arturo S. de Ocampo with Tax Identification No. (TIN) 270-717-714, Joel J. Sencida, Sr. (TIN 270-714-753), Hernan P. Maguale (TIN 270-715-193), Felomino Blanco, Sr. (TIN 270-715-900), Ismael Balceda (TIN 270-716-379) and Arturo Gelisanga, Sr. (TIN 270-716-969), collectively referred to as the Donors, are the registered owners of contiguous parcels of land covered by Original Certificates of Title (OCT) Nos. 179, 180, 181, 182, 183 and 184, respectively. The above-mentioned lots each have a 500 sq.m. area and are located in Barangay Bantayan, Kabankalan, Negros Occidental. On the other hand, Iglesia ni Cristo (Church of Christ) is a religious corporation with Securities and Exchange Commission (SEC) No. PW 287 and registered on July 27, 1914. It is a corporation sole whose properties are the church premises which include convents, rectories, cemeteries for the religious and bank deposits and shares of stock. On August 31, 2007, the Donors for and in consideration of their faith and deep abiding love as members of Iglesia ni Cristo executed deeds of donation of real property transferring in favor of the said Church the subject properties. In reply, please be informed that inasmuch as the donee is a religious organization, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (3) of the Tax Code of 1997, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Moreover, the deed of donation will not be subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but only to the documentary stamp tax of P15.00 imposed under Section 188 of the same Tax Code. HTcADC This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be ascertained that the facts are different, then this ruling shall be considered as null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service