PEOPLE OF THE PHILIPPINES v. RONALD PUNAY ROBIN Room 402 4th Floor, Champ Building, Bonifacio Drive Brgy. 650 Zone 068 Port Area Manila

CTA Form No.8 (For DCC) 11111 11 1111 11111111111~1111111 111 11~11111111 11111111111111111111111111 22-000638-0083 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA CRIM CASE NO. 0-1020 PEOPLE OF THE PHILIPPINES, NOTICE OF RESOLUTION Plaintiff, -versus- RONALD PUNAY ROBIN, Accused. To: PROSECUTOR GENERAL RICHARD ANTHONY D. FADULLO~ ASST. STATE PROSECUTOR JENNY A. DE CASTRO Depamnent ofJustice Padre Faura Street, Ermita, Manila 1000 ATTY. RAMON B. LORE~ZO ATTY. ROWELL B. VICE TE ATTY. KRISTINE ALMA T. CAYABYAB Bureau of Internal Revenue Legal Division, Revenue Region No. 6 5/F, BIR Building I, Solana Street lntramuros, Manila ATTY. SOCORRO MARICEL N. NEPO!VTUCENO (Co11nse/ for rhe Acc11sed) Mailbox No. I0-BC, Tower B Manhattan Heights, Barangay Socorro Cubao. Quezon City II 09 MR. RONALD PUNAY ROBIN o. 975 Joscfina, 3rd Street Brgy. 53 1, Zone 52, Sampaloc Manila GREETINGS: You are hereby notified by these presents that on September 25, 2025, a Resolution was rendered in the above-entitled case, copy of which is attached hereto . Quezon City, Philippines, September 29, 2025. Atty. Maria J~Chan-Te Executiv~ourt II Page I of I

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION PEOPLE OF THE CTA CRIM. CASE NO. 0-1020 PHILIPPINES, For: Violation of Section 255 of the Plaintiff, National Internal Revenue Code (NIRC) of 1997, as amended. -versus- Members: DEL ROSARIO, P.J., Chairperson, BACORRO-VILLENA, and CUI-DAVID, JJ. RONALD PUNAY ROBIN , Promulgated: Accused. SEP2 5 2025; /I: (Q~111 J{----------- ------------ --- -~---------- -J{ RESOLUTION CUI-~A VID, J.: This resolves plaintiff's Motion for Reconsideration on the Civil Aspect of the Case (Re: Decision dated April 23, 2025)1 ["Motion"], filed on May 8, 2025. The Motion seeks reconsideration of the civil aspect of the Decision2 promulgated on April 23, 2025 (assailed Decision), the dispositive portion of which reads: WHEREFORE, in light of the foregoing, accused RONALD PUNAY ROBIN is hereby ACQUITTED due to the failure prosecution to prove his guilt beyond reasonable doubt. There being no competent evidence to prove his civil liability, he is also exonerated from the same. Accordingly, the P60,000.00 cash bond posted by accused is cancelled pursuant to Section 22, Rule 114 of the Revised Rules of Criminal Procedure. The refund shall be processed only upon presentation of the Official Receipt and Docket, pp. 863-869. 2 /d. at 842- 862.

RESOLUTION CTA Crim. Case No. 0-1020 People of the Philippines v. Ronald Punay Robin X----------------------------------------------------------------------X shall be released to the person named therein or to the duly authorized representative, in accordance with En Bane Resolution No. 03-2009, Re: Guidelines on Reduction and Refund of Bail Bonds. SO ORDERED. In its Motion, plaintiff prays for a new decision affirming the validity of the assessments issued against accused and ordering him to pay the Bureau of Internal Revenue (BIR) the assessed deficiency taxes, inclusive of charges and penalties. Plaintiff raises the following grounds: I. WITH ALL DUE RESPECT, THE HONORABLE COURT ERRED IN RULING THAT THE PROSECUTION FAILED TO ADDUCE PROOF THAT ACCUSED AUTHORIZED DONALD REYES TO RECEIVE THE PAN AND THE FANs ON HIS BEHALF. II. FINALLY, THE HONORABLE COURT ERRED IN RULING THAT THE PROSECUTION FAILED TO ESTABLISH THE ACCUSED'S CIVIL LIABILITY. Despite being given the opportunity, accused did not file any objection or opposition to plaintiff's Motion. 3 Hence, the Court resolves. After a careful examination of the records and meticulous evaluation of plaintiff's arguments, the Court finds no sufficient and cogent reason to disturb its ruling in the assailed Decision. The issues raised in the instant Motion have already been thoroughly discussed and passed upon in pages 13-20 of the assailed Decision. To reiterate, the service of the Preliminary Assessment Notice (PAN), Formal Letter of Demand, and Final Assessment Notice (FAN) to Mr. Donald Reyes was improper. Moreover, there is no proof that the accused personally received these documents. This deficiency renders the assessment null and void. In the absence of a valid assessment, no criminal conviction or corresponding civil liability can arise for failure to pay tax under Section 255 of the National Internal Revenue Code of 1997, as amended. Records Verification Report dated June 30, 2025.

RESOLUTION CTA Crim. Case No. 0-1020 People of the Philippines v. Ronald Punay Robin x----------------------------------------------------------------------x WHEREFORE, premises considered, plaintiff's Motion for Reconsideration on the Civil Aspect of the Case (Re: Decision dated April 23, 2025) is DENIED for lack of merit. SO ORDERED. LANE~dt!AVID Associate Justice WE CONCUR: (On Leave) ROMAN G.DEL ROSARIO Associate Justice