QUEZON CITY and the OFFICE OF THE CITY TREASURER OF QUEZON CITY v. SKY CABLE CORPORATION

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Second Division QUEZON CITY and the OFFICE CTA AC NO. 295 OF THE CITY TREASURER OF [RTC Civil Case No. R-QZN-21- QUEZON CITY, 08820-CV] Petitioners, Members: -versus- RINGPIS-LIBAN, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JJ Promulgated: SKY CABLE CORPORATION, JAN Z 4 2025 Respondent. X ---------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: The Case For the Court's resolution is petitioners' Motion for Reconsideration, filed on November 5, 2024, with respondent's Comment/Opposition (to the Motion for Reconsideration dated 05 November 2024), filed on November 18, 2024. Petitioners seeks the setting aside of the Decision, dated October 8, 2024, which denied their Petition for Review. The Motion lacks merit. As observed by respondent, petitiOners merely rehash arguments already raised previously and thus already discussed and refuted. Rather than offer any defense of their interpretation of the Quezon City Revenue Code ("QCRC'), for example, petitioners double down on their insistence that the rulings of the Regional Trial Court render said law ineffective, a line of argument already dismantled in the assailed Decision. The same applies to majority of the other contentions included in the Motion.

RESOLUTION CTA AC NO. 295 Given that these contentions have already been shown to be wanting, there is no need to discuss them any further. 1 Petitioners did raise a few "new" points in response to certain specific statements in the Decision. However, these are still based on their faulty and yet undefended interpretation of the QCRC. They thus fail as well. ACCORDINGLY, the instant Motion for Reconsideration, filed on November 5, 2024, is hereby DENIED for lack of merit. The assailed Decision, dated October 8, 2024, is hereby AFFIRMED. SO ORDERED. MARIARO WE CONCUR: ~. ~ '> '-._ MA. BELEN M. RINGPIS-LIBAN Associate Justice co~ ~i?ifRRNI-F'ft~s Associate Justice See Roque v. Commission on Election, G.R. No. 188456 (Resolution), February I0, 20 I0; see also Shangri-La International Hotel Management, Ltd. v. Developers Group o.f Companies, Inc., G.R. No. 159938 (Resolution), January 22, 2007; see also Ortigas and Company Limited Partnership v. Velasco , G.R. Nos. 109645 & 11 2564 (Reso lution), March 4, 1996.