MISAMIS ORIENTAL RURAL ELECTRIC SERVICE COOPERATIVE I, INC (MORESCO-I), v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Second Division MISAMIS ORIENTAL RURAL CTA CASE NO. 10206 ELECTRIC SERVICE COOPERATIVE I, INC, Members: (MORESCO I), Petitioner, RINGPIS-LIBAN, Chairperson, and MODESTO-SAN PEDRO, and -versus- FERRER-FLORES, JJ COMMISSIONER OF Promulgated: Mr 2 INTERNAL REVENUE, Nov 1 1 zoz4 . ~ Respondent. . X ---------------------------------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Reconsideration (of the Decision dated July 16, 2024), filed on August 2, 2024, with no comment from petitioner. 1 Respondent assails this Court's Decision, dated July 16, 2024 ("assailed Decision"), which granted petitioner's Petition for Review. Preliminarily, the Court notes that the first half of the Motion simply rehashes arguments respondent already raised in his Memorandum. These have thus already been threshed out in the assailed Decision, so We need to discuss these once again. 2 What is new in this Motion is respondent's citing of BIR Ruling 779- 2019, as well as two cases decided upon by this Court's First Division, namely, Nueva Ecija 1 Electric Cooperative, Inc. v. Commissioner ofInternal Revenue3 and Zambales Electric Cooperative I, Inc. (ZAMECO I) v. Bureau ofInternal Revenue.4 However, neither BIR rulings nor even the decisions of/ See Records Verification, Rollo, unpaginated. See Roque v. Comm ission on Election, G.R. No. 188456 (Resolution), February I0, 20 10; see also Shangri-La International Hotel Management, Ltd. v. Developers Group ofCompanies, Inc. , G.R. No. 159938 (Reso lution), January 22, 2007; see also Ortigas and Company Limited Partnership v. Velasco , G.R. Nos. I09645 & 112564 (Resolution), March 4, 1996. CTA Case Nos. 10587 & 10632, November 13 , 2023. 4 CTA Case No. I0165, August I, 2023.

RESOLUTION CTA CASE NO . 10206 other Divisions of this Court are binding on this Court' s rulings. We thus find them insufficiently convincing to reverse Our previous ruling. Given that the Motion only raises (1) arguments that have already been discussed and refuted in the assailed Decision; and (2) citations of rulings that are not actually binding on this Court, We see no reason to grant it. ACCORDINGLY, the instant Motion for Reconsideration (of the Decision dated July 16, 2024), filed on August 2, 2024, is hereby DENIED for lack of merit. The assailed Decision, dated July 16, 2024, is hereby AFFIRMED. SO ORDERED. MARIARO WE CONCUR: ~ . ~ ~'-- MA. BELEN M. RINGPIS-LIBAN Associate Justice ~I#'� co~ONG. Associate Jusf