This article is for general information only and is not legal or tax advice. Estate matters are fact-specific; consult a Philippine lawyer and/or tax professional for your case.

1) The core rule: valuation is “as of the time of death”

In Philippine estate settlement and transfer, the foundational concept is that the estate is formed at the moment of death. As a result, the value of estate properties for estate tax purposes is generally determined at the decedent’s date of death, not today’s market price.

That said, “estate registration” in everyday conversation often lumps together multiple steps (BIR, local treasurer, Registry of Deeds, assessor’s office). Each step can use different bases for “value” and different documentary requirements, which is why people experience confusion.

A practical way to remember it:

Estate tax base (BIR) → generally date-of-death value
Transfer/registration fees and local transfer tax → often tied to fair market values and schedules used by the agency, and may feel “current,” even when the legal concept is still the value at transfer (death)
Real property tax / assessor’s records → based on the latest tax declaration/revision cycle, which may not match date-of-death values

2) What “value” means in estate cases (it’s not just “market price”)

When people say “market value,” they often mean what a buyer would pay today. In estate taxation and registration, the government typically uses defined “fair market value” standards depending on the property type.

A. Real property (land, house, condo)

For estate tax purposes, real property is generally valued using the fair market value (FMV) at the time of death, where FMV is typically determined as the higher of:

the BIR zonal value (BIR’s valuation per area), or
the FMV per the latest schedule of values / assessed value basis shown in the tax declaration (as maintained by the local assessor)

Key point: even though the rule is “time of death,” the practical evidence you present will be the government’s FMV references (zonal values, tax declarations, assessor schedules). Disputes often arise when the reference schedule changed between the date of death and the date you filed—more on that in Section 9.

B. Shares of stock

Listed shares are commonly valued using an exchange-based method around the date of death (often involving trading prices).
Unlisted shares are commonly valued using book value (based on the company’s financial statements) as of a relevant cut-off around death.

C. Bank deposits, cash, and similar financial assets

These are generally valued at the balance/amount as of the date of death (including accrued interest up to death, depending on documentation).

D. Vehicles and personal property

Valuation is usually based on an accepted FMV reference (appraisals, schedules, or credible documentation) tied to the condition and value at death.

E. Business interests, receivables, and other assets

Valuation depends on the nature of the asset and the best available evidence of FMV at death (financial statements, appraisals, contracts, collectability).

3) “Estate registration” is actually a chain of processes

Most families experience estate settlement as a sequence:

Settlement document
- Judicial settlement (court) or extrajudicial settlement (EJS) if allowed
BIR estate tax compliance (Estate Tax Return, payment if any, and issuance of CAR/eCAR)
Local Treasurer’s Office (transfer tax, if applicable in the LGU)
Registry of Deeds (transfer of title, issuance of new TCT/CCT in heirs’ names)
Assessor’s Office (transfer/update of tax declaration)

Each step may ask for a “value,” but not always for the same purpose.

4) The part everyone cares about: Estate tax computation uses date-of-death values

A. Gross estate is built from what the decedent owned at death

The gross estate generally includes the decedent’s properties and interests existing at death (subject to the usual estate rules on inclusion, conjugal/community property, etc.).

B. Net estate is gross estate minus allowable deductions

Common deduction concepts under Philippine estate tax practice include:

Standard deduction (a fixed amount allowed by law)
Family home deduction (up to a cap, if qualified)
Judicial expenses (if applicable)
Claims against the estate / unpaid obligations
Unpaid mortgages or encumbrances (subject to substantiation)
Share of the surviving spouse (in conjugal/community property regimes)
Other specialized deductions in specific circumstances

Important: Deductions have eligibility rules and documentary requirements. The “right” valuation base won’t help if deductions aren’t properly supported.

C. Tax rate concept

Philippine estate tax is generally computed as a percentage of the net estate (after deductions). If you’re computing historical or pending cases, confirm the applicable rules based on the date of death and the law in effect at that time.

5) If the property appreciated after death, do you pay tax on today’s higher value?

Generally, estate tax is based on values at death, so appreciation after death does not conceptually increase the estate tax base.

However, two realities complicate this:

The longer you delay, the more penalties may apply (interest/surcharges/compromise penalties, depending on the situation). You might not be taxed on appreciation, but you can still pay more due to penalties.
Government reference values may have been updated (new zonal values, updated assessor schedules). In practice, agencies may apply the value references they recognize at the time of filing unless you can clearly establish the proper date-of-death FMV basis and support it with acceptable documents.

6) “Current market value” can still matter—even if date-of-death valuation is the rule

Even when the estate tax base is date-of-death FMV, current value becomes relevant in several situations:

A. When heirs later sell the property

A later sale is a different taxable event. Taxes on the sale (e.g., capital gains tax or other applicable taxes depending on the asset) are generally based on the sale rules, not the estate valuation.

B. Partition fairness and heir negotiations

Heirs often use current values to negotiate an equitable partition—especially if some heirs will take cash while others take real property.

C. Registration fees and local transfer taxes may use schedules that feel “current”

Even if the legal concept is value at transfer, the fee computation often depends on the agency’s prevailing schedules and the documents they accept, which may not line up neatly with historical values.

D. Updating tax declarations and real property tax

The assessor’s office operates on local valuation schedules. Your new tax declaration after transfer can reflect updated values used for real property tax purposes going forward.

7) Real property specifics: “Zonal value” vs “tax declaration” and why the higher figure matters

For many estates, the fight is not “death vs current,” but which FMV reference produces the higher number.

Typical pattern:

If BIR zonal value is higher than the tax declaration basis, BIR usually uses the zonal value.
If the tax declaration’s FMV/assessor schedule is higher, BIR may use that higher local FMV.

Practical takeaway: before filing, heirs commonly check:

the property’s tax declaration and assessor data, and
the property’s zonal value classification

so they can anticipate the basis.

8) Common scenarios and what valuation usually applies

Scenario 1: Decedent died years ago; property value doubled since then

Estate tax concept: still anchored to date-of-death value
Risk: penalties for late filing/payment; and the agency may look to recognized FMV schedules unless you can support the proper basis.

Scenario 2: Property was improved after death (renovation, new structure)

Improvements after death generally belong to the estate/heirs period, not the decedent at death.
But documentation must clearly separate:
- what existed at death, and
- what was added after death
This matters for valuation, partition, and later sale tax issues.

Scenario 3: Estate includes conjugal/community property

Only the decedent’s portion is in the taxable estate, and the surviving spouse’s share is excluded (subject to the property regime rules). Valuation is still tied to death, but allocation matters.

Scenario 4: Multiple properties across different cities/provinces

Different LGUs mean different assessor schedules and local practices. Expect more document coordination and possible valuation inconsistencies across jurisdictions.

9) The “gotcha”: schedule changes between death and filing

A frequent pain point is this timeline:

Death occurred in Year X
Filing/processing happens in Year Y
Zonal values or assessor schedules changed in between

Even if the legal anchor is “time of death,” agencies may rely on the valuation references officially available to them during processing, unless:

you provide acceptable proof of what FMV reference applied at death, and
the office accepts applying that historical schedule to your filing

How people handle it in practice (risk-managed approach):

Gather documents that show the property’s classification and value references as close to the date of death as possible (old tax declaration copies, assessor certifications, etc.).
If the RDO or office insists on a higher current schedule, assess whether contesting it is worth the delay/cost versus paying under protest (where allowed) and pursuing remedies.

Because local practice varies, families often resolve this through direct coordination with the relevant RDO and local offices.

10) Documentary requirements heavily influence valuation outcomes

Valuation is not only a “rule”; it’s also what you can prove.

For real property, common documents include:

Certified true copy of title (TCT/CCT)
Latest tax declaration and tax clearance
Location map / vicinity map (sometimes)
BIR zonal value reference (as applicable)
Certificates of no improvement or building-related documents (if relevant)
Appraisals (sometimes helpful, sometimes not controlling)

For shares, deposits, and other assets:

Bank certifications as of date of death
Stock transfer agent certifications and financial statements
Vehicle registration documents and valuation references
Proof of receivables, collectability, contracts

11) Practical step-by-step: how families usually “price” property for estate processing

List all estate assets and identify which are exclusive vs conjugal/community
For each real property:
- get title, tax declaration, tax clearance
- determine the applicable zonal value classification
- compare likely FMV references
For bank accounts:
- request bank certification of balance as of date of death
For shares:
- secure certification and valuation basis (listed vs unlisted)
Build the estate tax computation, prepare substantiation for deductions
File and process BIR requirements, then proceed to LGU and Registry of Deeds
Update tax declarations after title transfer

12) Frequently asked questions

Q1: If I’m transferring the title now, won’t the Registry of Deeds use current value?

The Registry of Deeds and LGU often use their prevailing fee/tax bases and current schedules for administrative computation. This can look like “current market value,” even though estate tax valuation is conceptually tied to death. In practice, you may see different “values” appear on different receipts and forms.

Q2: Can we insist on the exact market price at the date of death?

You can try, but in many cases the government relies on standard FMV references (zonal values, assessor schedules, book value rules, bank balances). A private appraisal alone may not control, though it can support a position in some disputes.

Q3: If the property value dropped after death, can we use today’s lower price?

Conceptually, the valuation point is still time of death. A later drop doesn’t automatically reduce the date-of-death FMV, but if you can show that the property’s FMV at death was already lower (or that the reference classification was wrong), you may have an argument.

Q4: What if we discover an asset years later?

Undeclared assets can require amended compliance, and the timing/penalties can become complicated. Get professional advice immediately because the handling depends on the asset type, discovery timing, and what has already been processed.

Q5: Does “estate registration” mean the same thing as “estate tax”?

Not really. Estate tax is one part. “Estate registration” often includes BIR compliance, local transfer taxes, Registry of Deeds transfer, and tax declaration updates—each with its own rules and forms.

13) Bottom line

For Philippine estate tax purposes, property is generally valued at the time of death (date-of-death FMV).
The government often uses standard FMV references (e.g., zonal values and assessor/tax declaration values) and typically applies the higher recognized FMV reference for real property.
Even if the concept is “time of death,” administrative processing can feel like “current value” because schedules and fee bases may be updated by the time you file, and different offices compute fees/taxes differently.
Delays don’t usually tax appreciation as part of the estate base, but they can increase total cost through penalties and procedural friction.

If you tell me (1) the year of death, (2) the property type (house/lot, condo, shares, etc.), and (3) where the property is located, I can walk through how valuation is typically established for that specific asset class and which documents usually control.