Iii. Manila Race Horse Owners Association vs. Dela Fuente (88 Phil 60)

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ROSASENIA “ROSASENIA, Sweet Angela” Sweet Angela

This case involves a challenge to Manila Ordinance No. 3065, which imposed license fees on boarding stables for race horses based on the number of horses kept. The petitioner argued the ordinance was discriminatory and unconstitutional. The Court ruled the ordinance was not discriminatory, as it treated all similar stables equally. The number of horses was a fair method to determine the license fee amount, and race horse stables could reasonably be classified separately from other horse stables given the differences in their businesses and ability to pay taxes. Therefore, the ordinance did not violate the constitutional principle of equality and uniformity in taxation.

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Iii. Manila Race Horse Owners Association vs. Dela Fuente (88 Phil 60)

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ROSASENIA “ROSASENIA, Sweet Angela” Sweet Angela

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III. MANILA RACE HORSE OWNERS ASSOCIATION VS.

DELA FUENTE (88 PHIL 60)

DOCTRINE: There is equality and uniformity in taxation if all articles or kinds of property of the same class are taxed at the same rate.
SYNOPSIS:

FACTS:
Manila Race Horses Trainers Association, Inc. is a non-stock corporation duly organized and existing under and by virtue of the laws of the
Philippines, who allege that they are owners of boarding stables for race horses and that their rights as such are affected by Ordinance No.
3065.

Petitioner instituted an action for declaratory relief. It assails the validity of Manila Ordinance No. 3065, which imposed license fees to
stable owners based on the number of race horses kept, for being unconstitutional.

Petitioners argued that the ordinance was a tax on race horses as distinct from the stables, since the tax was based on the number of
horses in the stable. They also alleged that the same ordinance was discriminatory and was essentially a form of class legislation.

In addition, petitioner argued that the Municipal Board of Manila (is) without power to enact ordinance taxing private stables for race
horses,"

ISSUE:
WON Ordinance No. 3065 was discriminatory and unconstitutional

RULING:
NO. In taxing only boarding stables for race horse, the Court ruled that the ordinance do not make arbitrary classification.

There is equality and uniformity in taxation if all articles or kinds of property of the same class are taxed at the same rate.

Applying this criterion to the present case, there would be discrimination if some boarding stables of the same class used for the same
number of horses were not taxed or were made to pay less or more than others.

From the context of Ordinance No. 3065, the intent to tax or license stables and not horses is clearly manifest. The tax is assessed
not on the owners of the horses but on the owners of the stables,

It is also plain from the text of the whole ordinance that the number of horses is used in the assessment purely as a method of fixing
an equitable and practical distribution of the burden imposed by the measure. Far from being obnoxious, the method is fair and
just. It is but fair and just that for a boarding stable where only one horse is maintained proportionately less amount should be
exacted than for a stable where more horses are kept and from which greater income is derived

From the viewpoint of economics and public policy the taxing of boarding stables for race horses to the exclusion of boarding stables
for horses dedicated to other purposes is not indefensible.

The owners of boarding stables for race horses and, for that matter, the race horse owners themselves, who in the scheme of shifting may
carry the taxation burden, are a class by themselves and appropriately taxed where owners of other kinds of horses are taxed less or not at
all, considering that equity in taxation is generally conceived in terms of ABILITY TO PAY in relation to the benefits received by
the taxpayer and by the PUBLIC from the business or property taxed.

Race horses are devoted to gambling if legalized, their owners derive fat income and the public hardly any profit from horse racing,
and this business demands relatively heavy police supervision.

Taking everything into account, the differentiation against which the plaintiffs complain conforms to the practical dictates of justice and
equity and is not discriminatory within the meaning of the Constitution.