YMCA v. CIR, 33 Phil 217 (1916)

YMCA v. CIR, 33 Phil 217 (1916) ​

FACTS:

• The Young Men's Christian Association (YMCA) is a religious, charitable and educational institution combined. Its purpose is to develop the Christian character and usefulness of its members, to improve the spiritual, intellectual, social and physical condition of young men, and to acquire, hold, mortgage, and dispose of the necessary lands, buildings and personal property for the use of said corporation exclusively for religious, charitable and educational purposes, and not for investment or profit.
• It has a building located at Calle Concepcion, Ermita. The main structure is three stories high and includes a reception hall, social hall and game rooms, lecture room, library, reading room and rooming apartments. The second and third floors of the main building are given over almost wholly to rooming apartments and baths.
• The city of Manila, contending that the property is taxable, assessed it and levied a tax thereon.
• It was paid under protest and this action began to recover it on the ground that the property was exempt from taxation under the charter of the city of Manila.

ISSUE: 

• Whether or not the building and grounds of the Young Men's Christian Association of Manila are subject to taxation.

RULING:
YES, it is entitled to be exempted from taxation. The Young Men's Christian Association of Manila cannot be said to be an institution used exclusively for religious purposes, or an institution used exclusively for charitable purposes, or an institution devoted exclusively to educational purposes and there is no doubt about the correctness of the contention that an institution must devote itself exclusively to one or the other of the purposes mentioned in the statute before it can be exempt from taxation; but the statute does not say that it must be devoted exclusively to any one of the purposes therein mentioned. It may be a combination of two or three or more of those purposes and still be entitled to exempt.