SPEEDMAN CONSTRUCTION CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

CTA Form No. 8 (For DCC) 11111111111111111111111111111111 111111111111111111111111111111 11111 1111111111111 25-000790-0006 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRT DIVISION CTA CASE NO. SCA-0039 SPEEDMAN CONSTRUCTION CORPORATION, Petitioner, -versus- NOTICE OF RESOLUTION COMMISSIONER OF INTERNAL REVENUE, Respondent. To: SPEEDMAN CONSTRUCTION CORPORATION Unit 87, Future Point Plaza I 11 2 Panay Avenue, South Triangle, Quezon City GREETIN GS: You are hereby notified by these presents that on November 21, 2025, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, November 25, 2025. Atty. Maria Jo ~ Chan-Te Executive C ~ourt III

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS Quezon City FIRST DIVISION SPEEDMAN CONSTRUCTION CTA SCA CASE NO. 0039 CORPORATION, Members: Petitioner, -versus- BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID , JJ. COMMISSIONER OF Promulgated: � NOV 2 2025, INTERNAL REVENUE, O~:Jo~~/ J Respondent. -s ------------ X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - C_ - X RESOLUTION On 12 September 2025, petitioner Speedman Construction Corporation (petitioner/SCC) filed a Verified Petition for Certiorari, beseeching this Court to nullify respondent Commissioner of Internal Revenue's (respondent's/CIR's) Decision dated 02 September 2025 for having been issued with grave abuse of discretion amounting to lack or excess of jurisdiction. Per Records Verification dated 16 September 2025, this Court's Judicial Records Division (JRD) certified that petitioner failed to file an email/soft copy of the Verified Petition for Certiorari and its Annexes within twenty-four (24) hours from the filing of the hard or paper copy on 12 September 2025, in violation of Section 2, paragraph 21 of En Bane Resolution No. 8-20242 , adopting A.M . No. 10-3-7-SC and A.M. No. 11-9-4-SC3 (eFiling Guidelines). 2. Manner oftransmittal. -The PDF copies must be transmined by litigants and court users to the official e-mai l addresses: When the primary manner of fi li ng is through personal fi ling, by registered mail, or by accredited courier, in accordance with Ru le 13, Section 3(a), 3(b), or 3(c) of the 2019 Amendments to the 1997 Rules of Civi l Procedure, ten (I 0) paper cop ies for En Bane cases, and six (6) paper copies for initiatory pleadings or four (4) paper copies for subsequent pleadings for Division cases, shall be filed. The PDF copies must be transmined within twenty-four (24) hours from such filing of paper copies; otherwise, tlt e pleading or court submission sitall be deemed as notfiled. Guidelines on Submission of Electronic Copies of Pleadings and Other Court Submissions Before the Court ofTax Appeals Pursuant to A.M. No. 10-3-7-SC and A.M. No. 11 -9-4-SC. RE: GUIDELINES ON SUBM ISSION OF ELECTRON IC COPIES OF PLEADINGS AND OTHER COURT SUBM ISSIONS BEING FILED BEFORE THE LOWER COURTS PURSUANT TO THE EFFICIENT USE OF PA PER RULE/MOVING TOWARDS DIGITAL COURTS: COM PONENT ONE: TRANSITION TO ELECTRONIC FILI NG AND SERVICE OF

RESOLUTION CTASCA CASE NO. 0039 Speedman Construction Corporation v. Commissioner of Internal Revenue x- - - - ----- -- - - - ------- ------- --- ------ - - - --- - - - -- - - ---- - - -x In addition to this Court's adoption of the eFiling Guidelines through En Bane Resolution No. 8-2024, the Supreme Court's Resolution dated 26 November 2024 on Rule 13-A of the Rules of Civil Procedure (RCP), as amended, or the "Interim Rule on the Electronic Filing and Service of Pleadings Judgment, and Other Papers in Civil Cases" (Interim Rule), which took effect on 01 December 2024, provides that no court shall act upon an initiato ry pleading unless it is accompanied by an electron ic transmittal. If such electronic transmittal is not completed within the prescribed 24-hour period, the initiatory pleading shall be deemed not filed , to wit: SECTION 3. Manner of filing of complaints and other initiatory pleadings. - The filing of complaints and other initiatory pleadings shall be done by: a. Submitting personally the original paper, plainly indicated as such, to the court; b. Sending the paper by registered mail; or, c. Sending the paper by accredited courier. After the complaint or initiatory pleading has been filed through any of the three modes provided in the first paragraph of th is Section , the filing party shall subsequently email t he complaint or initiatory pleading in digital file format to the court. Digital copies of the additional accompanying documents of the complaint or initiatory pleading, such as annexes, appendices, or exhibits, shall likewise be emailed . The electronic transmittal of the complaint or initiatory pleading and the accompanying documents must be made within 24 hours from the completeness of the primary mode of the complaint or initiatory pleading's filing. The term "digital file format," wh en used to refer to pleadings, papers, and other documents, shall mean the portable document format. No court shall act upon any complaint or initiatory pleading unless the latter's filing is accompanied by the electronic transmittal required in the third paragraph of this Section. If the electronic transmittal is not completed before the period, the complaint or initiatory pleading shall be deemed not filed, regardless of the completeness of the primary mode of its filing .4 PLEA DINGS, MOTIONS AN D OTH ER DOCU MENTS AS WELL AS DIG ITAL SERVICE OF AL L O RDE RS IN C IV IL CASES. Emphasis and underscoring supplied.

RESOLUTION CTA SCA CASE NO. 0039 Speedman Construction Corporation v. Commissioner of Internal Revenue Page 3 of3 x---------------- - ------------------------------------- -- -x Accordingly, for petitioner's failure to comply with the electronic transmittal requirement within the prescribed 24-hour period , as mandated under En Bane Resolution No. 8-2024 in relation to the Interim Rule, the instant Verified Petition for Certiorari dated 12 September 2025 is hereby DEEMED NOT FILED. SO ORDERED. LA~~ID Associate Justice