Religious Corporation Cannot Qualify as a Donee or Legatee

February 9, 1980 BIR RULING NO. 018-80 Messrs. C. J. Valdez & Associates San Andres Street, Paco, Manila Gentlemen : This refers to your letter dated September 19, 1978 requesting certification of your client's the Roman Catholic Archbishop of Manila, qualification as a donee or legatee entitled to the benefits provided for in Presidential Decree No. 507. Documentary evidence submitted to this Office shows that your client is a non-stock, non-profit religious corporation duly registered with the Securities and Exchange Commission organized for the purpose of administering the temporalities and the properties of the Roman Catholic Church within its territorial jurisdiction or archdiocese. In reply thereto, I regret to inform you that your client being a religious corporation cannot qualify as a donee or legatee under Presidential Decree No. 507, which specifies only three kinds of organization that can avail of the benefits provided for in said law, namely: charitable, cultural and social welfare organization. (BIR Ruling No. 75-007 dated January 14, 1975). Very truly yours, EFREN I. PLANA Acting Commissioner