15. [This item has two questions.] Philippine Medical Center (PMC) is a government hospital created by law to provide healthcare to the general public, especially the less fortunate. To enable PMC to perform its mandate, the national government provided the initial capital, land, buildings, and equipment to PMC. PMC’s charter also authorized it, acting through its Board of Trustees: to acquire property; to enter into contracts; to mortgage, encumber, lease, sell, convey, or dispose of its properties; and to do other acts necessary to accomplish its purposes and objectives. Among the properties of PMC are five lands and buildings located in Quezon City. The Quezon City assessor issued notices of assessment for real property taxes (RPT) against PMC’s properties that are being leased to private concessionaires. According to the city assessor, PMC’s properties leased to private entities are subject to RPT because these properties are not being exclusively used for charitable purposes. PMC, on the other hand, claims that, as a government instrumentality imbued with corporate powers, it is exempt from RPT.