AEON CREDIT SERVICE (PHILIPPINES) INC. v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY THIRD DIVISION AEON CREDIT SERVICE CTA Case No. 10693 (PHILIPPINES) INC., Petitioner, Members: -versus- MANAHAN, Chairperson, REYES-FAJARDO, and ANGELES, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, FEB 0 3 2.025 Respondent. X - - - - - - - - - - - -0::-:-:.-:- _I_;f!IJ: _e':_~: - - - - - - X --------- RESOLUTION Before this Court is petitioner's Motion for Reconsideration (Ofthe Resolution dated 22 July 2024) filed on August 13, 2024, without respondent's comment. Petitioner asserts the following in the instant motion: (1) The instant case is not on all fours with the Wintelecom case; (2) The delay between the actual date of filing of petitioner's Formal Offer of Evidence (FOE) and the date prayed for its filing in its Motion for Extension of Time is not significant or substantial; (3) The rigid application of procedural rules undermines the pursuit of substantial justice; (4) The Court's mandate in ensuring that cases are decided on the merits is better served if the Court allows petitioner to formally offer its evidence; and (5) The summary denial of petitioner's subject motion deprives it of its right to due process.

RESOLUTION CTA Case No. 10693 After careful consideration, the Court resolves to deny the present motion. To reiterate, petitioner filed its first Motion for Extension (MotEx) on May 16, 2024, to extend the date of the filing of its FOE until May 26, 2024. Yet, even the second MotEx was belatedly filed on May 27, 2024. In both instances, counsels for petitioner advanced the excuse of "heavy workload" to justify the delay in its filing. Evidently, petitioner's inexcusable laxity in observing its own prayer in the subject motion, i.e., to extend the filing of its FOE until May 26, 2024, and yet filing the second MotEx one (1) day late on May 27, 2024 due to "heavy workload," clearly undermines the power of the Court to control the proceedings which contributes to the needless delay and derailment of the speedy administration ofjustice. Hence, the Court finds no error in the assailed Resolution denying: (1) petitioner's first and second MotEx; and (2) the admission of the subject FOE. FOR THESE REASONS, petitioner's Motion for Reconsideration (Of the Resolution dated 22 July 2024) is DENIED, for lack of merit. SO ORDERED. C~7�4-�~--- cATHERINE T. MANAHAN Associate Justice ~ ~ F. ~ -ft;tfM~ MARIAN rVYJF. RErtS:FAJ'ARDO Associate Justice HENRY ~~ANGELES Associate Justice