BUREAU OF INTERNAL REVENUE V. ZIEGFRIED LOO TIAN (No. 1013, Juan Luna Street, Brgy. 7, Zone 1, Tondo Manila)

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane PEOPLE OF THE PHILIPPINES, CTA EB CRIM. N0.106 Petitioner, (CTA Crim. Case No. 0-948) Present: -versus- DEL ROSARIO, P.J., RINGPIS-LIBAN, MANAHAN, BACORRO-VILLENA, MODESTO-SAN PEDRO, R EYES -FA J ARDO , CUI-DAVID, FERRER-FLORES, and ANGELES,JJ ZIEGFRIED LOO TIAN, Promulgated : Respondent. JUl 1 1 202~ X ---------------------------------------------------------------------- ----------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's "Motion for Reconsideration (ofthe Decision dated Janumy 09, 2024)," filed via registered mail on January 30, 2024, with respondent's "Comment/Opposition" thereto, filed on April 3, 2024. Petitioner seeks the reversal of Our Decision, dated Januaty 9, 2024 ("Assailed Decision") which denied its Amended Verified Petition for Review, fi led via registered mail on July 10, 2023 . The Motion is bereft of merit. First, petitioner's argument on the deputization of special prosecutors from the Bureau of Internal Revenue ("BIR") does not in any way contradict Our ruling that the Department of Justice ("DOJ") remained as either the primary prosecutor or at least one of the collaborating prosecutors in this casey

RESOLliTIO:\ CTA �8 Crim. No. 106 (CTA Crim. Case No. 0-9,18) Page2of3 To repeat, the DOJ never ceased being counsel to the People of the Philippines, and the deputization of special prosecutors from the BIR did not change that. As such, the date on which the BIR learned of this case is irrelevant-what is controlling for the prescriptive period at issue here is the date on which the DOJ received the Comi in Division's December 5, 2022 Resolution. Second, petitioner's contentions on the prescriptive period for filing an Information before the Comi in Division, which are a mere rehash of the arguments earlier raised in the Petition for Review and already refuted in the Assailed Decision, are once again silent on Rule 9, Section 2 of the Revised Rules of the Court of Tax Appeals. As they leave an integral part of Our reasoning unaddressed, these arguments can be similarly ignored. Lacking any points that actually challenge Our findings in the Assailed Decision, the Motion for Reconsideration cannot be granted. ACCORDINGLY, petitioner's Motion for Reconsideration (of the Decision dated January 09, 2024) is hereby DENIED for lack of merit. The assailed Decision, dated January 9, 2024, is hereby AFFIRMED. SO ORDERED. MARIARO WE CONCUR: Presiding Justice ~. ~ ../)'-- MA. BELEN M. RINGPIS-LIBAN Associate Justice r.I ~ lkloMo,�....~.t~-- CATHERINE T. MANAHAN Associate Justice

RESOUTION CTA EB Crim. No. 106 (CTA Crim. Case No 0-948) Pagc3of3 ~ . BACORRO-VILLENA ociate I ustice ~~f.~ -foj~tb MARIAN Iik F. RE~ES-FAJARDO Associate Justice LAN~:P.[~~VID Associate I ustice HENRY ~GELES Associate Justice