ILOILO City — The Supreme Court En Banc has dismissed the petition challenging Iloilo City’s real property tax (RPT) adjustments under Iloilo City Tax Ordinance (TO) No. 2023-226, citing the petitioners’ procedural lapses and their failure to follow established legal remedies.
In its decision promulgated on January 28, 2026, the High Court ruled that the petition raised largely factual issues, including the validity of the assessment process and the economic impact of the revised property values.
The High Court emphasized that such matters fall within the jurisdiction of lower courts and administrative bodies equipped to evaluate evidence and technical data.
“Jurisprudence has been consistent in dealing with challenges against increased real property assessment levels. The adjudication of the substantive and procedural merits of real property assessments has been assigned by law to specialized administrative agencies which have the technical expertise to deal with the factual issues and masses of empirical data involved in land valuation and realty taxation,” the decision read.
The petitioners in the case are lawyers Teodoro B. Pison and Rosalinda L. Pison of Riverside Holdings Corporation, and Riverside Boardwalk Properties Inc.
The ruling, penned by Associate Justice Samuel H. Gaerlan and concurred in by Chief Justice Alexander G. Gesmundo and the members of the Court En Banc, further stated that “following the hierarchy of courts, the adjudication of pure questions of law arising from the real property assessment process is assigned by law to the trial courts, not to the Supreme Court.”
It also found that the petitioners failed to exhaust administrative remedies available under the Local Government Code, including appeals before the Secretary of Justice and assessment protests. Instead, they filed the case directly before the Supreme Court, bypassing mandatory procedures.
In its submission, the Iloilo City Government maintained that the petitioners failed to overcome the presumption of validity accorded to local ordinances. It argued that TO No. 2023-226 is a valid exercise of the city’s lawmaking, taxing, and police powers, enacted in compliance with state audit recommendations, particularly as Iloilo City’s assessment values had lagged behind neighboring localities.
The city government also emphasized that the ordinance complied with procedural due process requirements under the Local Government Code and its implementing rules. It submitted documentary proof of public consultations, committee hearings, posting of the proposed measure in conspicuous places, and publication in newspapers of general circulation.
Further, the city asserted that the updated assessment values reflect prevailing market conditions and were based on data from financial institutions and real estate sources.
The revised schedule was likewise reviewed and approved by the Department of Finance’s Bureau of Local Government Finance. It added that the increase in property values corresponds to actual market trends in Iloilo City.
The SC’s decision also highlighted that real property valuation is a technical process governed by specialized agencies and must align with Republic Act No. 12001, or the Real Property Valuation and Assessment Reform Act (RPVARA), which mandates local government units to follow standardized valuation rules and implementing guidelines.
Citing the law, the Court noted that all real properties must be appraised based on prevailing market values in accordance with the Philippine Valuation Standards.
It also emphasized the requirement for local assessment offices to regularly update schedules of market values and observe the prescribed revision cycle.
“As it now stands, LGUs are duty-bound to follow the provisions of the RPVARA and its implementing rules in the conduct of real property valuation and assessment,” the Court said.
With the dismissal of the petition, Iloilo City Tax Ordinance No. 2023-226 remains in full force and effect./PN
