October 14, 2009
BIR RULING [NSNP-(S30H-107) 643-09]
par. 3, Sec. 4 Art. XIV, 1987 Constitution
Holy Infant Academy of Calapan
Ilaya, Calapan City, Oriental Mindoro
Attention: Ms. Minda Fetejos
Gentlemen :
This refers to your letter dated September 23, 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. EcASIC
Documentary evidence submitted disclosed that Holy Infant Academy of Calapan with Tax Identification Number 001-900-254 is a non-stock, non-profit educational institution duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. 546 dated May 27, 1937 and further amended on May 7, 1987 and that it is duly recognized by the Department of Education in accordance with Government Recognition No. 466 Series of 1947 and K-064 Series of 1998.
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...