YMCA vs. CIR, 33 Phil. 217 (1916) G.R. No. L-7988, January 19, 1916

Fact: The Young Men’s Christian Association came to the Philippine with the army of occupation in 1898. When the large body of troops in Manila was removed to permanent quarters at Fort William McKinley in February, 1905, an independent association for Manila was organized under the direction of the Army and navy departments. Shortly after the organization of the association the directors made a formal request to the international committee of the Young Men’s Christian Association in New York City for the assistance and cooperation of its foreign department. A site for the new building was selected on Calle Concepcion, Ermita, and the building contract was let on the 8th of January following. The cornerstone was laid with appropriate ceremonies on July 10, 1908, and the building was formally dedicated on October 20, 1909.

The purposes of the association, as set forth in its charter and constitution, are:

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.

The purposes of this association shall be exclusively religious, charitable and educational, in developing the Christian character and usefulness of its members and in improving the spiritual, mental, social and physical condition of young men.

Issue: Whether the building and grounds of the Young Men’s Christian Association of Manila are subject to taxation Exemption?

Held: Yes, There is no doubt about the correctness of the contention that an institution must devote itself exclusively to one or the other of the purpose 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. 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; but we believe it can be truthfully said that it is an institution used exclusively for all three purposes, and that, as such, it is entitled to be exempted from taxation.