GR No.

L-15334, 31 January 1964

RULES
1. Land, buildings, roads, and constructions of all kinds
adhered to the soil; xxx xxx
3. Everything attached to an immovable in a fixed manner; in
such that it cannot be separated therefrom without
breaking the material or deterioration of the object; xxx xxx
5. Machinery, receptacles, instruments or implements
intended by the owner of the tenement for an industry or
works which may be carried in a building or on a piece of
land, and which tends directly to meet the needs of the said
industry or works; xxx xxx
Par. 9, part 2 of Act. No. 484 (MERALCO’s franchise) 3
 Granting of
franchise to Under protest, MERALCO
operate and paid real property tax and
maintain electric filed petition for review in
and power system CTA
24 Mar. 1903
29 Dec. 1958
15 Nov. 1955
CTA held that steel
City Assessor declared
towers are personal
steel towers for real
properties and not
property tax and
subject to real property
ordered payment for
tax
1952-1956
CONCLUSION (not real properties)
1. The steel towers are not constructions
analogous to buildings nor adhering to
the soil; they are removable and merely
attached to a square metal frame by
means of bolts, which when unscrewed
could easily be dismantled and moved
form place to place.
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CONCLUSION (not real properties)
3. Each of the steel towers or supports
consists of steel bars or metal strips,
joined together by means of bolts, which
can be disassembled by unscrewing the
bolts and reassembled by screwing the
same.

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CONCLUSION (not real properties)
5. Manila Electric Company is not engaged
in an industry or works on the land in
which the steel towers are constructed.

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CONCLUSION (not real properties)

Under MERALCO’s franchise (Act.

No. 484), the term “pole”, which is
exempted from taxes and assessment,
should not be given a restrictive and
narrow interpretation. Thus, the steel
towers should fall under the exemption.
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