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The Mindanao Bus Company appealed a real property tax assessment on its maintenance and repair equipment by the City Assessor of Cagayan de Oro City. The Court of Tax Appeals upheld the assessment, finding the equipment constituted real property. However, the Supreme Court reversed, holding that to be considered real property under Philippine law, equipment must be essential to carrying out the industrial purpose for which a property was established, which was not the case for tools used to service transpor

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