cta_resolution CTA Case No. 1230212302 2026-04-23

GEOSCIENCE TECHNOLOGIES, INC. as represented by Armie P. Camince v. COMMISSIONER OF INTERNAL REVENUE ROMEO D. LUMAGUI, JR.

,... REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SECOND DIVISION GEOSCIENCE TECHNOLOGIES, CTA Case No. 12302 Members: INC. as represented by Armie P. Camince, Petitioner, -versus- BACORRO-VILLENA, Chairperson, and CUI-DAVID, JJ. COMMISSIONER OF INTERNAL REVENUE ROMEO D. LUMAGUI JR., Promulgated: Respondent. ;.: X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -~ - - - - - - - X RESOLUTION r . r C) r~~ In the Minute Resolution dated 16 January 2026, which petitioner received on 22 January 2026, petitioner was ordered, inter alia, to submit a Verification and Certification Against Forum Shopping that is compliant with Rule 7, 1 Section 4 of the Rules of Civil Procedure (RCP), as amended. Instead of submitting a compliant verification and certification within the period given, petitioner filed the following pleadings: a. "Motion for Extension to Submit Compliance (to the 16 January 2026 Minute Resolution) with Utmost Apologies," filed via courier on 29 January 2026 and received by this Court on 30 January 2026; b. "Motion for Extension to Submit Compliance (to the 16 January 2026 Minute Resolution) with Utmost Apologies," filed via courier on 02 February 2026 and received by this Court on 04 February 2026; Parts and Contents of a Pleading.

RESOLUTION CTA Case No. 12302 Geoscience Technologies, Inc. as represented by Armie P. Camince v. Commissioner of Internal Revenue Romeo D. Lumagui Jr. X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X c. "Motion to Admit Supplemental Pleadings to the Petition for Review (dated 29 December 2025) with Partial Compliance to the Minute Resolution (dated 22 January 2026)," filed via courier on 11 February 2026 and received by this Court on 13 February 2026; and d. "Motion to Admit Affidavit in Full Compliance to the Minute Resolution (dated 16 January 2026)," filed via courier on 18 February 2026 and received by this Court on 19 February 2026. Despite these submissions, the Court notes that petitioner still did not submit a revised Verification and Certification Against Forum Shopping that complies with Rule 7, Section 4 of the RCP, as amended, as expressly required. The Court refers to the Verification and Certification2 executed by affiant Armie Panambo Camince for petitioner: 1. I am the Attorney-in-Fact of GEOSCIENCE TECHNOLOGIES, INC., the Petitioner in this case by virtue of Secretary Certificate dated 29 December 2025. 2. In such capacity, I have caused the preparation and filing of the foregoing Petition for Review with Manifestation and Motion to Suspend Collection of Taxes and I hereby verify and attest that the allegations therein are true and correct based on what were relayed to me by the Petitioner himself and/or based on authentic records at hand and made available to me. 3. The said Petition for Review with Manifestation and Motion to Suspend Collection of Taxes is not filed to harass, cause unnecessary delay, or needlessly increase the cost of litigation. 4. The factual allegations therein have evidentiary support after reasonable opportunity for discovery. 5. I hereby certify that I have not commenced any other action or proceeding or any claim, or filed any claim involving the same issues raised in the above-captioned case other than the case mentioned in the preceding paragraphs in the Supreme Court, in the Court of Appeals, nor in the different Divisions thereof, nor in any other court or tribunal or agency and, to the best of my knowledge, no such other action or claim is pending therein, and; Division Docket, p. 27.

' i RESOLUTION CTA Case No. 12302 Geoscience Technologies, Inc. as represented by Armie P. Camince v. Commissioner of Internal Revenue Romeo D. Lumagui Jr. X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X 6. If I should learn that a similar action or proceeding has been filed or pending in the Supreme Court, in the Court of Appeals, nor in the different Divisions thereof, nor in any other court, or tribunal or agency, I hereby undertake to inform this Honorable Court of such fact within five (5) days from such notice. 3 Rule 7, Section 4 of the RCP, as amended, provides: SECTION 4. Verification. - Except when otherwise specifically required by law or rule, pleadings need not be under oath or verified. A pleading is verified by an affidavit of an affiant duly authorized to sign said verification. The authorization of the affiant to act on behalf of a party, whether in the form of a secretary's certificate or a special power of attorney, should be attached to the pleading, and shall allege the following attestations: (a) The allegations in the pleading are true and correct based on his or her personal knowledge or based on authentic documents; (b) The pleading is not filed to harass, cause unnecessary delay, or needlessly increase the cost of litigation; and (c) The factual allegations therein have evidentiary support or, if specifically so identified, will likewise have evidentiary support after a reasonable opportunity for discovery. The signature of the affiant shall further serve as a certification of the truthfulness of the allegations in the pleading. A pleading required to be verified that contains a verification based on "information and belief," or upon "knowledge, information and belief," or lacks a proper verification, shall be treated as an unsigned pleading. 4 As the Court previously found, petitioner's Verification and Certification Against Forum Shopping was defective. Accordingly, petitioner was directed to submit a Verification and Certification that fully complies with Rule 7, Section 4 of the RCP, as amended. Despite the Court's directive and successive motions for extension and motions Emphasis supplied. 4 Emphasis and underscoring supplied.

1 RESOLUTION CTA Case No. 12302 Geoscience Technologies, Inc. as represented by Armie P. Camince v. Commissioner of Internal Revenue Romeo D. Lumagui Jr. X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X to admit supplemental pleadings/affidavit, petitioner still failed to submit a revised and compliant Verification and Certification Against Forum Shopping. Section 3, Rule 175 of the RCP, as amended, provides that a case may be dismissed for failure of the plaintiff to comply with any order of the Court. WHEREFORE, premises considered, petitioner Geoscience Technologies, Inc.'s, as represented by Armie P. Camince, "Petition for Review with Manifestation and Motion to Suspend Collection of Taxes," filed on 05 January 2026 is DISMISSED without prejudice. SO ORDERED. ..._ JEAN MA LA~~ID Associate Justice Section 3. Dismissal due to fault ofplaintiff - If, for no justifiable cause, the plaintiff fails to appear on the date of the presentation of his or her evidence in chief on the complaint, or to prosecute his or her action for an unreasonable length of time, or to comply with these Rules or any order of the court, the complaint may be dismissed upon motion of the defendant or upon the court's own motion, without prejudice to the right of the defendant to prosecute his or her counterclaim in the same or in a separate action. This dismissal shall have the effect of an adjudication upon the merits, unless otherwise declared by the court. (Emphasis and underscoring supplied)

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