September 22, 2009
BIR RULING [NSNP-(S30H-101) 601-09]
Par. 3, Sec 4 (3), Art. XIV, 1987 Constitution
Good Shepherd Academy of Victoria
Poblacion II, Victoria, Oriental Mindoro
Attention: Mrs. Adahlia Adalia
Gentlemen :
This refers to your letter dated July 10, 2009 requesting for tax exemption as a non-stock, non-profit educational institution pursuant to Section 4 (3), Article XIV of the 1997 * Philippine Constitution.
Documentary evidence submitted disclosed that the Good Shepherd Academy of Victoria with Tax Identification Number 003-938-771 is a non-stock, non-profit educational institution duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. 33226 dated August 31, 1967 and that it is duly recognized by the Department of Education in accordance with Government Recognition No. 30 Series of 1971.
In reply, please be informed that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides, viz.:
"(3) All revenues and assets of non-stock, non-profit educational institutions used actually, directly and exclusively for educational purposes shall be exempt from taxes and duties. . . ."
The exemption under Section 4 (3), Article XIV of the 1987 Constitution is self-executing....