This case has been cited 1 times or more.
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2000-10-12 |
QUISUMBING, J. |
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| Tax assessments by tax examiners are presumed correct and made in good faith, with the taxpayer having the burden of proving otherwise.[10] In the instant case, petitioner failed to show that the use by the LBAA and CBAA of the APT floor bid price, pursuant to Section 3 (n) of the Real Property Tax Code was incorrect and done in bad faith. The method used by the LBAA and CBAA cannot be deemed erroneous since there is no rigid rule for the valuation of property, which is affected by a multitude of circumstances and which rules could not foresee nor provide for.[11] Worthy of note, petitioner has not shown that the current market value of its properties would be significantly lower if its proposed formula is adopted. A party challenging an appraiser's finding of value is required not only to prove that the appraised value is erroneous but also what the proper value is.[12] Factual findings of administrative agencies, which have acquired expertise in their field, are generally binding and conclusive upon the Court.[13] The Court will not presume to interfere with the intelligent exercise of the judgment of men specially trained in appraising property.[14] Where the judicial mind is left in doubt, it is a sound rule to leave the assessment undisturbed.[15] In this case, we see no reason to depart from this rule. | |||||