Manotok v.

Barque FACTS: Petitioners, (respondents herein) as the surviving heirs of the late Homer Barque, filed apetition with the LRA for administrative reconstitution of the original copy of ! "o# $%&%''issued in the name of Homer L# Barque, which was destroyed in the fire that gutted the(ue)on !ity Hall, including the *ffice of the Register of +eeds of (ue)on !ity, sometime in%,--# .n support of the petition, petitioners su/mitted the owner0s duplicate copy of ! "o# $%&%'', real estate ta1 receipts, ta1 decla2rations and the Plan 3L4 5%6- + covering theproperty#7pon /eing notified of the petition for administrative recon2stitution, private respondents(petitioners herein) filed their opposition thereto claiming that the lot covered /y the titleunder reconstitution forms part of the land covered /y their reconsti2tuted title ! "o# R 2$$8-%, and alleging that ! "o# $%&%'' in the name of petitioners0 predeces2sors2 in2interest is spurious# ISSUE: 9hether or not irregularly issued titles can /e cancelled /y the LRA: HELD: Respondents levied on a portion of the ;A<RA to satisfy the ta1 delinquency of P"*!2 =+!#However, the land /eing levied is classified as inaliena/le# .t is owned /y the governmentand thus, cannot /e sold at pu/lic auction# Li>ewise, the machineries, equipment and otherinfrastructures in the ;A<RA cannot /e levied and sold at pu/lic auction /ecause it is notthe property that is su/?ect to the ta1# he personal lia/ility for the ta1 delinquency, is generally on whoever is the owner of thereal property at the time the ta1 accrues@ where, however, the ta1 lia/ility is imposed on the/eneficial use of the real property such as those owned /ut leased to private persons orentities /y the government, or when the assessment is made on the /asis of the actual usethereof, the personal lia/ility is on any person who has such /eneficial or actual use at thetime of the accrual of the ta1#.n the case at /ar, P"*!2 =+! is the /eneficial user, however, since respondents cannot availof the administrative remedy through levy, they can only enforce the collection of realproperty ta1 through civil action#P"*!2=+! also claims that the real property ta1 assessment is not yet final and e1ecutory# .tavers that prior resort to administrative remedies /efore see>ing ?udicial remedies is not necessary considering that the issue raised is purely a question of law# !onsequently, itneed not appeal the assessment to the Local Board of Assessment Appeals or to the !entralBoard of Assessment Appeals as provided under 4ections $$6$' and $$,$of the L<!#9e disagree# .t is well2settled in 4ystems Plus !omputer !ollege of !aloocan !ity v# Local<overnment of !aloocan !ity$, that all adminis2trative remedies must /e e1hausted /eforeavailing of the ?udicial remedies# husA he petitioner cannot /ypass the authority of the concerned administrative agencies anddirectly see> redress from the courts even on the prete1t of raising a supposedly purequestion of law without violating the doctrine of e1haustion of administrative remedies#Hence, when the law provides for remedies against the action of an administrative /oard,/ody, or officer, as in the case at /ar, relief to the courts can /e made only after e1haustingall remedies provided therein# *therwise stated, /efore see>ing the intervention of thecourts, it is a precondition that petitioner should first avail of all the means afforded /y theadministrative processes#.f P"*!2=+! was not satisfied with the assessment of its property, it should have appealedto the Local Board of Assessment Appeals within 6& days from receipt of the written noticeof assessment# .nstead, it waited until the issuance of a warrant of levy /efore it filed apetition for in?unction in the regional trial court, which was not in accordance with theremedies provided in the L<!#9H=R=3*R=, the petition is PAR .ALLB <RA" =+# he +ecision and *rder of the Regional rial !ourt are A33.R;=+ insofar as it declared P"*!2=+! lia/le to pay the real property ta1accruing from its use of the ;A<RA# Respondents however are +.R=! =+ to refrain fromlevying on the /uildings, infrastructures and machineries of P"*!2 =+! to satisfy thepayment of the real property ta1 delinquency#