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Question
During the current calendar year, the City Assessor of the Municipality of Bantay issues a real property tax assessment against a parcel owned by Rosa Santos. The assessment notice lists the parcel description, the classified rate, and the total amount due, but the notice provides no hearing or opportunity to contest the assessment prior to levy. The Municipal Treasurer later issues a warrant of distraint and levy on Rosa's bank account to collect the tax. Rosa files a verified complaint for prohibition and injunction in the trial court, arguing that the assessment is void for lack of due process. (a) Identify the central doctrine governing the validity of local tax assessments in the Philippines. (b) Applying that doctrine, determine whether the absence of prior hearing renders the assessment void and why. (c) State the proper remedy for Rosa to challenge the assessment and stop collection, and what relief the court should grant.