BIR Ruling No. 153-61

May 10, 1961 BIR RULING NO. 153-61 11th Indorsement Returned to the Regional Director, Regional District No. 9, Zamboanga City. prll It appears from the papers of the case that the Notre Dame Hospital, Cotabato City, is owned and operated by the Congregacion Religiosa St. Catalina de Cena, a religious corporation duly organized under the laws of the Philippines and registered with the Securities and Exchange Commission. In the St. Luke's Hospital Case which is also owned and operated by a religious corporation, our Supreme Court held that the maintenance of a hospital is part of the religious or charitable work of the religious organization. Our Supreme Court, therefore, held in said case that the income of the corporation from the operation of the hospital is exempt from the income tax. The doctrine in said case finds application in the instant case. As to the maintenance by the corporation of the pharmacy department of the hospital the corporation is also exempt from the graduated annual fixed tax if it can be established that it sells medicine only to patients. (Collector vs. St. Paul's Hospital of Iloilo, G.R. No. L-12127.) Under the same principle, the corporation must necessarily have to be exempted from the retail dealer of narcotic drugs privilege tax. cdta It may be stated in this connection that all professionals, such as the doctors and nurses employed in said hospital, are also exempt from the occupation tax if it can be duly established that the said professionals render their entire professional services exclusively to the hospital. (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue By: (SGD.) MISAEL P. VERA Deputy Commissioner of Internal Revenue