BAHAY BONDS 2 SPECIAL PURPOSE TRUST, administered by Land Bank of the Philippines through its Trust Banking Group v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OFTAX APPEALS QUEZON CITY THIRD DIVISION BAHAY BONDS 2 SPECIAL CTA Case No. 10475 PURPOSE TRUSL Members: ADMINISTERED BY NATIONAL MANAHAN, Chairperson, REYES-FAJARDO, and HOME MORTGAGE FINANCE ANGELES/JL CORPORATION, Petitioner/ - versus - Promulgated: COMMISSIONER OF INTERNAL -JAN 0 5 2026 REVENUE, - - r:~ ?' � - . Responden t . X- -- --- - ---- -- - - - ---- --- --- - - - -- - ------ -- --- ------- -X RESOLUTION REYES-FAJARDO, J.: For the Court's resolution is respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 13 September 2024),1 posted on October 4/ 2024. It mainly seeks to reverse the Court's Decision promulgated on September 13/ 2024/2 which partially granted petitioner's refund in the reduced am ount of P1,656,000.00 representing erroneously paid final withholding taxes (FWT) on interest income arising from petitioner's fixed-rate notes or the "Bahay Bonds 2" relative to the period from November 26, 2018 to December 4/ 2020. The fallo of which reads: 3 WHEREFORE, in light of the foregoing considerations, the consolidated Petitions [sic] for Review filed by Bahay Bonds 2 Special Purpose Trust is PARTIALLY GRANTED. Respondent Com missioner of Interna l Reve nu e is ORDERED to refund or iss ue Rollo, pp. 573 - 579. 2 Td. a t pp. 559 - 572. 3 !d. a l p. 571.

RESOLUTION CTA CASE NO. 10-175 a tax credit certificate in favo r of petitioner in the reduced amount of Pl,656,000.00 representing erroneously paid final withholding taxes on interest inco me arising from the Fixed Rate No tes, collectively known as " Bahay Bonds 2" between the first quarter of 2019 to the fourth quarter of 2020. SO ORDERED. In its Motion for Partial Reconsideration (Re: Decision promulgated on 13 September 2024), p etitioner contends that: (1) the Bahay Bonds 2 are not exempt from taxes because they constitute d eposit substitutes pursuant to Bureau of Internal Revenu e (BIR) Ruling No. 516-2012 and Section 22(Y) of the National Internal Revenue Code of 1997 (NIRC); and (2) the BIR's construction of Section 22(Y), being the interpretation of the government agency tasked with implementing tax laws, should be accorded great weight. Respondent, through its Comment (On Responden t's 23 September 2024 Motion for Partial Reconsideration)-! filed on May 20, 2025, and admitted5 on June 25, 2025, retorts that petitioner's motion is pro forma, as the m atters raised were mere rehash, which had ah"eady been passed upon by the Court. It reiterates the Court ruling, which h eld that Bahay Bonds 2 are not considered as deposit substitutes. We find for petitioner. The Court has already held that petitioner's Bahay Bonds 2 are n ot dep osit substitutes. Section 31 of Republic Act (RA) No. 9267, otherwise kn own as "The Securitization Act of 2004," explicitly provides that asset-backed securities issued by a special purpose entity pursuant to an approved plan "shall n ot be considered as deposit substitutes." The Court likewise determined that the Bahay Bonds 2 qualify as asset-backed secu rities within the meaning of RA No. 9267. In Ortigas and Company Limited Partnership v . Judge Tirso Velasco and Dolores V. Molina, and Dolores V. Molina v. Han. Presiding Judge of RTC, Quezon City, Br. 105, and Manila Banking Corporation,6 it was h eld that a Court is not bound to discuss each argument in a motion for reconsideration that merely reiterates matters already resolved, an d may properly be dealt with in a general manner, viz.: 4 Rollo, pp. 603- 608. 5 Itt., p. 612. o G.R. Nos. 1096-!5 and 11256-t, Reso lution, March -!, 1996.

RESOLUTION CfA CASE N O. 10.f75 Pa ge 3 of 3 Effect, mrrt Disposition of Motio11 for Reco11siderntio11 The filing of a motion for reconsideration, authorized by Rule 52 of the Rules of Co urt, does not impose on the Court the obligation to deal indiv iduall y and specifi cally with the grounds reli ed upon therefor, in much the same way that the Co urt does in its judgment or final order as regards be issues raised and submitted for decision. This would be a useless fo rm ality or ri tual invariably involving merely a reiteration of the reasons alread y set forth in the judgment or final order for rejecting the arguments advanced by the mova nt; and it would be a needless act, to o, with res pect to issues raised for the first tim e, these being, as above stated, deemed waived because not asse rte d at the first opportunity. It suffices for the Court to deal genera lly and summarily with the motion for reconsideration, and merely state a legal ground for its denial (Sec. 14, ART. VITI, Co nstitution); i.e., the motion contains merely a reiteration or rehash of arguments already submitted to and pronounced w ithout merit by the Court in its judgmen t, or the basic issues have already been passed upon, or the motion. discloses no substantial argument or cogent reason to warrant reco nsid era tion or modification of the judgment or final order; or the arguments in the motion are too unsubsta ntial to require consideration, etc. WHEREFORE, petitioner's Motion for Partial Reconsideration (Re: Decision promulgated on 13 September 2024) is DENIED for lack of merit. The Decision promulgated on September 13, 2024, is AFFIRMED. SO ORDERED. r.. {'~ ~;......~0....Nit.."'Aer----- CATHERINE T. MANAHAN Associate Justice ~ ~ f.~ -fa.irwh MARIAN rVYfJ. REYEg-FAJA'RDO Associate Justice /JJL HENRYS. ANGELES Associate Justice