COMMISSIONER OF INTERNAL REVENUE v. HEALTH PLAN PHILIPPINES, INC.

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTAEB NO. 3134 REVENUE, (CTA Case No. 10262) Petitioner, Present: -versus- RINGPIS-LIBAN, P.J. , BACORRO-VILLENA, MODESTO-SAN PEDRO, REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and ANGELES, JJ. HEALTH PLAN PHILIPPINES, Promulgated: INC., Respondent. X ---------------------------------------------------------------------------------------- X RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner' s Motion for Reconsideration (Decision dated 5 December 2025), filed via licensed courier on December 19, 2025, with respondent's Opposition [Re: Motion for Reconsideration dated 19 December 2025}, filed via licensed courier on January 5, 2026. The Motion assails this Court's Decision, dated December 5, 2025, which dismissed the instant Petition for non-compliance with procedural requirements laid down in the Revised Rules ofthe Court of Tax Appeals, as amended ("RRCTA"). Petitioner insists that it did not violate respondent's due process rights as the latter was given an opportunity to protest the assessment against it. Respondent counters this by observing that the Motion merely rehashes arguments already rejected by this Court and by emphasizing the importance of the 15-day grace period granted to taxpayers to respondent to a Preliminary Assessment Notice~

RESOLlTIO>; CTA EB No. 313-1- (Cr;\ Case 0Jo. 10262) Page 2 of3 It does not escape the Court's notice that the contents of the Motion are irrelevant to Our ruling. While We covered petitioner's violation of respondent's due process rights in the assailed Decision, such discussion was merely an academic aside. The actual ruling was the dismissal of the case on procedural grounds, on which the Motion is completely silent. It is as if petitioner did not even read the Decision against him. Having nothing to say about the procedural grounds for the dismissal of the case, the Motion raises nothing that is actually related to the Decision as promulgated. Respondent continues to insist that the ruling of the Court in Division was in error but says nothing at all about the ruling of the Court En Bane. He thus raises no relevant reason to modifY the ruling of the Court En Bane. Considering this failure, the assailed Decision stands. ACCORDINGLY, petitioner's Motion for Reconsideration (Decision dated 5 December 2025), filed via licensed courier on December 19, 2025, is hereby DENIED for lack of merit. The Decision, dated December 5, 2025, is AFFIRMED. SO ORDERED. MARIA RO,~ENA -SAN PEDRO f Associate ustice WE CONCUR: ~. -1!. l~op~ ~ ----- MA. BELEN M. RINGPIS-LIBAN Presiding Justice JEAN MARIE so iate Justice ~ ~ t~-t~~ MARIAN IVY ilREvEs-ttAJARDO Associate Justice

RESOLlTIO:-; CTA F.B No.3 13-l- (CTA Case No. 10262) Page 3 of3 LAkltL{:AblAlA.~AU'I&-nD�AVID Associate Justice co~tc~~~ Associate Justice HENRYd~GELES Associate Justice CERTIFICATION Pursuant to Article VIII, Section 13 of the Constitution, it is hereby certified that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court. ~- 4.A.4._ .... - MA. BELEN M. RINGPIS-LIBAN Presiding Justice