FACTS:

City Assessor of QC declared the steel towers for real property tax under Tax Declarations.  After denying the respondent’s petition to cancel these declarations, an appeal was taken with the CTA which held that the steel towers  come  under  the  exception  of  “poles”  under  the  franchise  given  to MERALCO; the steel towers are personal properties; and the City Treasurer is liable for the refund of the amount paid.
 

HELD:

The steel towers of an electric company don’t constitute real property for the purposes of real property tax.