i. Against Assessment

Remedies Against Real Property Tax Assessments

Unpaid real property tax attaches to the property but is directly chargeable against the taxable person having actual and beneficial use and possession¹. Consequently, a beneficial user who is legally burdened with the tax payment possesses the legal interest and personality to protest an assessment or claim exemption (National Power Corporation v. Province of Pangasinan and the Provincial Assessor of Pangasinan, G.R. No. 210191, 24 February 2020)¹. However, in specific cases such as that of the University of the Philippines under Republic Act No. 9500, which superseded Sections 205(d) and 234(a) of the Local Government Code, there is no longer a need to ascertain the tax status of the possessor or beneficial user to establish exemption, provided the asset is owned by the university and used for or in support of educational purposes (University of the Philippines v. City Treasurer of Quezon City, G.R. No. 214044, 19 June 2019)².

An assessment or tax declaration may also be nullified if issued outside the taxing authority's territorial jurisdiction³. As held in City Government of Tagaytay v. Urban Property Holdings, Inc., G.R. No. 272201, 11 August 2025, a local government unit has no right to collect real estate taxes on properties outside its territorial boundaries, and courts act within their authority in nullifying tax declarations or auction sales involving such extraterritorial properties³. Furthermore, a local government unit is conclusively presumed to know the law delineating its territorial boundaries and acts in bad faith when it levies real estate taxes outside its jurisdiction³.

While parties with legal standing may challenge assessments or assert exemptions, courts must also recognize that the right of local government units to collect taxes is upheld to prevent severe revenue erosion and ensure genuine, meaningful local autonomy to finance basic services essential to the general welfare under the Local Government Code¹.