No. The term "educational institution" or
"institution of learning" has acquired a well-known technical
meaning.
Under the Education Act of 1982, such term refers to schools. The school system is synonymous
with formal education, which
"refers to the hierarchically structured and chronologically graded
learnings organized and provided by the formal school system and for which
certification is required in order for the learner to progress through the
grades or move to the higher levels." The
Court has examined the "Amended Articles of Incorporation" and
"By-Laws" of the YMCA, but found nothing in them
that even hints that it is a school or an educational institution.
Furthermore, under the Education Act of 1982, even non-formal education
is understood to be school-based and "private auspices such as foundations
and civic-spirited organizations" are ruled out. It is settled that the term
"educational institution," when used in laws granting tax exemptions,
refers to a ". . . school seminary, college or educational establishment .
. . ." Therefore, the
private respondent cannot be deemed one of the educational institutions covered
by the constitutional provision under consideration.
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