DOJ Opinion No. 002, s. 1991

DOJ OPINION NO. 002 , s. 1991 January 4, 1991 Administrator Pelayo J. Gabaldon National Food Authority 101 E. Rodriguez Avenue Quezon City Sir : This has reference to your request for opinion on the following queries: "(a) Whether or not NFA's real estate tax exemption privilege was withdrawn with the passage of P.D. 1931 and Executive Order No. 93 and therefore, it incurred back taxes? (b) If the answer to the above is in the affirmative, did Executive Order No. 93 restore NFA tax-exemption from the time it was promulgated in December 17, 1986 up to the present?" We are constrained to refrain from expressing our views on your queries, it appearing that the same involve the tax-exempt status of National Food Authority (NFA) which properly falls within the jurisdiction of the Secretary of Finance. Pursuant to settled precedents, the Secretary of Justice has consistently refrained form expressing his views on matters which over which the Secretary of Justice possesses no revisory authority (Secretary of Justice Ops., No. 379, s. 1976; No. 1, s. 1983; No. 60, s. 1987; No. 97, s. 1982; No. 123, s. 1980 and No. 169, s. 1979). Nonetheless, we invite attention to Secretary of Justice Opinion No. 56, s. 1990 (copy enclosed) which you may find relevant to your query. Please be guided accordingly. Very truly yours, (SGD.) FRANKLIN M. DRILON Secretary