MANILA ELECTRIC CO. V. CENTRAL BOARD OF ASSESSMENT APPEALS
114 SCRA 273
FACTS:
Petitioner owns two oil storage tanks, made of steel plates wielded and assembled on the spot. Their bottoms rest on a foundation consisted of compacted earth, sand pad as immediate layer, and asphalt stratum as top layer. The tanks merely sit on its foundation.The municipal treasurer of Batangas made an assessment for realty tax on the two tanks, based on the report of the Board of Assessors. MERALCO wished to oppose this assessment as they averred that the tanks are not real properties.
HELD:
While the two storage tanks are not embodied in the land, they may nevertheless be considered as improvements in the land, enhancing its utility and rendering it useful to the oil industry.For purposes of taxation, the term real property may include things, which should generally be considered as personal property. it is familiar phenomenon to see things classified as real property for purposes of taxation which on general principle may be considered as personal
property.