CALFURN MFG. PHILIPPINES INCORPORATED, ASIA RATTAN MFG. COMPANY, AWECA EXIM TRADING CORPORATION, AIM-EX ASIA INT`L TRADING CORPORATION, AWECA CARGO SERVICES, INC., and AWECA AGRO-FOREST INDUSTRIES CORPORATION v. JULIET QUINSAAT in her capacity as City Treasurer of Angeles City, Pampanga

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC CALFURN MFG. CTA EB No. 2953 (CTA AC No. 253) PHILIPPINES Present: INCORPORATED* and RINGPIS-LIBAN, 1?.1 AWECA CARGO SERVICES, BACORRO-VILLENA, MODESTO-SAN PEDRO, INC., REYES-FAJARDO, CUI-DAVID, Petitioners, FERRER-FLORES, and, -versus- ANGELES, JJ. JULIET G. QUINSAAT in her capacity as City Treasurer of Promulgated: Angeles City, Pampanga, Respondent. rJ UN 0 3 2026 x---------------------------------------------------x RESOLUTION REYES-FAJARDO, J.: For action are the following incidents: a. Petitioners' Motion for Reconsideration filed through accredited courier on February 18, 2026; b. Petitioners' Electronic Transmittal of Documents; and c. Petitioners' Prayer for Liberal Application of the Rules.

RESOLUTION CTA EB No. 2953 (CTA AC No. 253) Motion for Reconsideration filed through accredited courier on February 18, 2026 Records Verification Report1 dated February 24, 2026 disclosed that petitioners failed to transmit a Portable Document Format copy of their Motion for Reconsideration, within 24 hours from the filing thereof via accredited courier on February 18, 2026, as required by CTA En Bane Resolution No. 8-2024,2 in relation to CTA En Bane Resolution No. 1-2025.3 In view thereof, petitioners' Motion for Reconsideration is DEEMED NOT FILED. Electronic Transmittal of Documents Petitioners' electronic transmittal of the following documents is NOTED, viz.: Document Date of Electronic Transmittal Motion for Reconsideration March 13, 2026 March 13, 2026 Manifestation March 16, 2026 Compliance/Motion for March 17,2026 Reconsideration Compliance/Motion for Reconsideration (with Submission of Soft Copy and Prayer for Liberal Application of the Rules) Prayer for Liberal Application of the Rules Petitioners' Prayer for Liberal Application of the Rules must be rejected. * The following petitioners in CTA AC No. 253, namely: (1) Aim-Ex Asia Int'l Trading Corporation; (2) Asia Rattan Mfg. Company; (3) Aweca Exim Trading Corporation; and (4) Aweca Agro-Forest Industries Corporation, were merged with Calfurn Mfg. Philippines Incorporated. Rollo, unpaginated. 2 Guidelines on Submission of Electronic Copies of Pleadings and Other Court Subm.issions Before the Court of Tax Appeals Pursuant to A.M. No. 10-3-7-SC and A.M. No. 11-9-4-SC (September 1, 2024). 3 Interim Guidelines on the Submission of Electronic Copies of Pleadings and Other Court Submissions Before the Court of Tax Appeals (February 5, 2025).

RESOLUTION CTA EB No. 2953 (CTA AC No. 253) Page 3 of4 For one, sifting through petitioners' Compliance/Motion for Reconsideration (with Submission of Soft Copy and Prayer for Liberal Application of the Rules)4 shows that they failed to state, much more, prove their valid justification, as to their non-adherence with the filing of electronic copies of their motions within the 24- hours from filing thereof, as required in CTA En Bane Resolution No. 8-2024, in relation to CTA En Bane Resolution No. 1-2025. For another, the case-law cited by petitioners militates against their cause. In United Airlines v. Uy (Uy), 5 therein respondent's belated filing of notice of appeal by two (2) days, was excused " ... due to the unique and peculiar facts of the case and the serious question of law it poses."6 Too, in Samala v. Court of Appeals (Samala)/ when the belated appeal by one (1) day was considered excusable due to the stomach pains of the person tasked to file it. What we can refract from Uy and Samala is that therein parties were relieved of the adverse consequence of failure to observe the mandatory periods of appeal because of peculiar facts, or excusable circumstance. Additionally, the delay in the filing thereof is, at most, two (2) days from the prescribed deadline. In contrast, on top of the dearth of proof of facts wqtthy of leniency, petitioners filed electronic copies of their motion for reconsideration at the earliest, on March 13, 2026. This is twenty-two (22) days late from the deadlines for submission of an electronic copy thereof on February 19, 2026. Thus, petitioners are undeserving of the liberality they desired. ACCORDINGLY, We RESOLVE to: a. DEEM as NOT FILED, petitioners' Motion for Reconsideration filed through accredited couner on February 18, 2026; 4 Rollo, unpaginated. Compliance/Motion for brevity. G.R. No. 127768, November 19, 1999. Cited in paragraph 5 of petitioners' Compliance/Motion. 6 Boldfacing ours. 7 G.R. No. 128628, August 23, 2001. Cited in paragraph 5 of petitioners' Compliance/Motion. 8 24 hours from filing of petitioners' Motion for Reconsideration on February 18, 2026.

RESOLUTION CTA EB No. 2953 (CTA AC No. 253) Page 4 of4 b. NOTE petitioners' electronic transmittal of the documents found in the table under page 2 of this resolution; and c. DENY petitioners' Prayer for Liberal Application of the Rules, for lack of merit. SO ORDERED. ~~r.~-F~ MARIAN IVY F. REYES-FAJARDO Associate Justice WE CONCUR: Jy. ~r-- MA. BELEN M. RINGPIS-LIBAN Presiding Justice PEDRO LAN~itD1vm Associate Justice 7 co~cf~E~ES Associate Justi;~... HENRY ~GELES Associate Justice