COHACO MERCHANDISING DEVELOPMENT CORP. v. THE CITY GOVERNMENT OF MUNTINLUPA, represented by HON. JAIME R, FRESNEDI, THE SANGGUNIANG PANLUNGSOD OF MUNTINLUPA CITY, THE CITY TREASURER OF MUNTINLUPA and THE CITY ATTORNEY`S OFFICE OF MUNTINLUPA

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION COHACO MERCHANDISING CTA AC NO. 207 DEVELOPMENT CORP., Petitioner, Members: -versus- DEL ROSARIO, P.J. , Chairperson, and MANAHAN, JJ. THE CITY GOVERNMENT OF MUNTINLUPA, represented by HON. JAIME R. FRESNEDI, THE SANGGUNIANG PANLUNGSOD OF MUNTINLUPA CITY, THE CITY TREASURER OF MUNTINLUPA and THE CITY ATTORNEY'S OFFICE OF Promulgated: MUNTINLUPA, Respondents. OCT 0 8 20 X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RESOLUTION For resolution is petitioner's Motion for Reconsideration filed on July 20, 2020, with respondents' Comment and/or Opposition (To Motion for Reconsideration, dated 20 July 2020) filed through email on September 18, 2020.1 Petitioner seeks reconsideration of the Decision dated June 23, 2020 (assailed Decision),2 the dispositive portion of which reads: "WHEREFORE, the instant Petition for Review filed by Cohaco Merchandising Development Corp. is hereby DENIED, for lack of merit. Accordingly, the assailed Decision dated January 30, 2018 and Order dated May 30, 2018 of the Regional Trial Court - 1 Respondent's Comment and/or Opposition was also received by the Court on September 21, 2020 sent via private courier. 2 Docket, pp 134-155.

RESOLUTION CTA AC NO. 207 Branch 276 in Civil Case No. 17-294 are AFFIRMED on grounds stated herein. SO ORDERED." Petitioner moves for reconsideration of the assailed Decision based on the following grounds: 1. The increase in the tax rate is beyond the allowable adjustment under Section 191 of the Local Government Code (LGC); 2. Tax rates may be adjusted once every five years only; and, 3. Assuming that Ordinance No. 13-030 is valid, it should not be applied retroactively as it will be violative of Section 166 of the LGC. Respondents, on the other hand, argue that petitioner's motion should be denied based on the following arguments: 1. The Motion should be denied for being a pro-forma pleading; 2. The tax rates are in accordance with the LGC; and, 3. Ordinance Nos. 013-015 and 013-030 are presumed valid. Acting on petitioner's Motion for Reconsideration of the Decision dated June 23, 2020, the Court notes that no new argument has been adduced to warrant the� reconsideration sought. The arguments interposed by petitioner are mere rehash of the arguments it raised in its Petition for Review filed on July 11, 2018 and Memorandum filed on February 4, 2019 which have all been squarely passed upon and resolved by the Court. WHEREFORE, premises considered, petitioner's Motion for Reconsideration filed on July 20, 2020 is hereby DENIED for lack of merit. SO ORDERED. Presiding Justice I CA~ THERI- NE ~- ANAHA~ N Associate Justice