PEOPLE OF THE PHILIPPINES v. MENGJUN ZHU, (426 Balabac Street, Ayala Alabang Village, Muntinlupa City) and SU YONGCHANG (426 Balabac Street, Ayala Alabang Village, Muntinlupa City) (both At-Large)

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL SECOND DIVISION PEOPLE OF THE PHILIPPINES, CTA CRIM. CASE NO. 0-1359 Plaintiff, For: Violation of Section 1401(g), in -versus- relation to Sections 400, 1113 and 1118, of Republic Act No. 10863 (CMTA) Members: MENGJUN ZHU, RINGPIS-LIBAN, Chairperson, ,----- (426 Balabac Street, Ayala Alabang MODESTO-SAN PEDRO, and Village, Muntinlupa City) and FERRER-FLORES, JJ SU YONGCHANG, (426 Balabac Street, Ayala Alabang Promulgated: Village, Muntinlupa City (both At-Large), Accused. X----------------------- -- ----------------\-1-- -'-]'-i-1f"--�-------------X RESOLUTION Before the Court is the prosecution's Motion for Reconsideration filed on December 2, 2025. On September 5, 2025, the prosecution filed the Information dated June 10, 2025 against herein accused MENGJUN ZHU and SU YONGCHANG for violation of Section 1401(g) in relation to Sections 400, 1113, and 1118, of Republic Act (R.A.) No. 10863, otherwise known as the Customs Modernization and Tariff Act (CMTA), with attached supporting documents. In the Minute Resolution dated November 4, 2025, the Court found that the prosecution failed to electronically file the pdf copy of the Information, pursuant to En Bane Resolution No. 8-2024 (Guidelines. on Submission ofElectronic Copies ofPleadings and Other Court Submissions Before the Court of Tax Appeals Pursuant to A.M No. 10-3-7-SC and A.M

RESOLUTION CTA CRIM. Case No. 0-1359 Page 2 of3 No. 11-9-4-SC). Said Information was, thus, deemed not filed and the present case was considered closed and terminated. Hence, the filing of the present Motion for Reconsideration. The prosecution implores the Court to reconsider the Minute Resolution dated November 4, 2025 as the docket section of its office inadvertently failed to electronically file the copy of the Information due to heavy workload. The instant Motion for Reconsideration is unwarranted. The Court of Tax Appeals (CTA) issued En Bane Resolution No. 8- 2024, 1 which requires that, when the primary manner of filing is by personal filing, registered mail, or accredited courier, the PDF copy of the pleading or court submission shall be transmitted within 24 hours from such filing of the paper copy; otherwise, the pleadings or court submissions shall be deemed not filed. Under Item 2 on the Manner of Transmittal in the said En Bane Resolution, an initiatory pleading shall be filed personally, by registered mail, or by accredited courier. Hence, its PDF copy must be transmitted within 24 hours from the filing via personal filing, by registered mail or accredited courier. Here, the Information was personally filed on September 5. 2025. Two months after, or on November 4, 2025, the Court noted that no PDF was transmitted via email within 24 hours; hence, the Information was deemed to have not been filed and the case was closed and terminated. The prosecution only transmitted the PDF copy of the Information upon its filing of the instant Motion for Reconsideration on December 4, 2025. A perusal of the records shows that the prosecution only emailed on December 4, 2025 the Information without its enclosures and/or supporting documents. The Court finds no reason to relax the rules of procedure. To be sure, the relaxation of procedural rules cannot be made without any valid reasons 1 Guidelines on Submission of Electronic Copies of Pleadings and Other Court Submissions Before the Court of Tax Appeals Pursuant to A.M. No. 10-3-7-SC and A.M. No. 11-9-4-SC, effective September 1, 2024.

� RESOLUTION CTA CRIM. Case No. 0-1359 Page 3 of3 proffered for or underpinning it. To merit liberality, petitioner must show reasonable cause justifYing its non-compliance with the rules and must convince the Court that the outright dismissal of the petition would defeat the administration of substantive justice.2 Here, the prosecution moves for the reconsideration of the minute resolution for its allegedly inadvertent failure to electronically file the Information due to its heavy workload. Clearly the prosecution failed to show any reasonable cause to justify its noncompliance with the rules. Merely claiming heavy workload cannot be considered as a reasonable cause that would justifY the reversal of the minute resolution closing the terminating the case for failure to comply with En Bane Resolution No. 8- 2024. The desired leniency cannot be accorded absent valid and compelling reasons for such a procedurallapse.3 ACCORDINGLY, in view thereof, the instant Motion for Reconsideration is DENIED for lack of merit. SO ORDERED. ~-~- MA. BELEN M. RINGPIS-LIBAN Presiding Justice MARIA ROWJ,l:N~ IAssoci 2 Daikoku Electronics ?hils., inc. vs. Raza, G.R. No. 181688, June 5, 2009. 3 !d.