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Abra Valley College vs Aquino, 162 SCRA 106 (1988)
Whether the lot and building and questionnaire used exclusively for educational purposes.
The exemption in favor of property used exclusively for charitable or educational purposes is not limited to property “actually indispensable” but extends to facilities which are incidental to and reasonably necessary for the accomplishment of said purposes. The test of exemption from taxation is the use of the property for purposes mentioned in the Constitution. The phrase “exclusively used for educational purposes” has always been made that exemption extends to facilities which are incidental to and reasonably necessary for the accomplishment of the main purposes.
The second floor being used for residential purposes of the director and his family may be justified but the list of the first floor thereof to Northern Marketing Corporation cannot by any stretch of imagination be considered incidental to the purpose of education However, since only a portion is used for purposes of hammers it is only fair that half of the assessed tax be returned to the school involved