CTA Case No. 5781 (Decision)

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY GOODYEAR PHILIPPINES, INC., Petitioner, -versus- C.T.A. CASE NO. 5781 COMMISSIONER OF INTERNAL Promulgated: REVENUE, 0CT0 3 2002 Respondent. X--------------------------------------------------�--~ ~~\ DECISION This judicial action involves a claim for refund or issuance of a tax credit certificate in the amount of P6,695 ,518.00 allegedly representing overpaid income tax for the calendar year ended December 31 , 1996. The antecedent facts follow. Petitioner is a domestic corporation duly registered and organized under ~- Philippine laws, with principal office located at Old National Road, Barangay Almanza, � ""~>;, Las Pinas, Metro Manila. It is a corporation primarily engaged in the manufacture and sale of tires and rubber products (Stipulated Fact, Item No. 1, CTA docket, p.3 7) . On April 15, 1997, petitioner filed with the Bureau of Internal Revenue its Corporation Annual Income Tax Return for calendar year ended December 31 , 1996,

DECISION CTA Case No. 5781 Page2 paying the corresponding tax due thereon in the amount of P 32,803,360.00 (Stipulated Fact, Item No. 3, CTA docket, p .38), detailed as follows : Gross Income p 909,504,420.00 Less: Deductions Taxable Income 269,408,683.00 Tax Rate Tax Due p 640 ,095 ,737.00 Less: Tax Credits/Payments Tax Payable 35% p 224 ,033 ,508.00 191,230,148.00 p 32!803!360.00 On March 30, 1999, Petitioner filed an Amended Corporation Income Tax Return (Exhibit B) for the same calendar year ended December 31 , 1996, which reflected a revised income tax payable in the amount of P 26,107,842.00 (Stipulated Fact, Item No. 4, CTA docket, p.38), computed as follows: Gross Income p 909,504,420.00 Less: Deductions Taxable Income 269,408,683.00 Tax Rate Tax Due p 640 ,095 ,737.00 Less: Tax Credits/Payments Tax Payable 35% p 224,033,508.00 197,925,666.00 p 26!107!842.00 Petitioner explained that the discrepancy in the income tax payable was due to the fact that it inadvertently recorded its tax credits or payments for 1996 as P191 ,230,148.00 instead ofP197,925,666.00 because it failed to recognize the additional creditable income tax withheld on its sale of goods for 1996 in the amount of P6,695,518.00. This made

DECISION CTA Case No. 5781 Page3 the petitioner pay mcome tax m the amount of P32,803 ,360.00 instead of only P26,107,842.00. Thus, on April 8, 1999, petitioner, through its tax counsel Sycip, Gorres, Velayo & Co., filed with the Bureau of Internal Revenue a claim for refund of excess or overpaid income tax for the year ended December 31 , 1996 in the amount of P6,695,518.00 (Stipulated Fact, Item No. 5, CTA docket, p.38). As the claim of petitioner was not immediately acted upon by the respondent, the former elevated its case to this court by way of petition for review on April 14, 1999 to forestall the running of the two-year prescriptive period. In answer to the instant petition, respondent raised the following special and affirmative defenses, to wit: 1. "In an action for tax refund, petitioner must show that taxes were paid erroneously or collected illegally. Failure to sustain this burden is fatal to the action for refund; 2. Claims for refund are construed strictly against the claimants since they are in the nature of exemptions from taxation (Manila Electric Co. vs. Commissioner oflntemal Revenue, 67 SCRA 351); 3. Taxes are presumed to have been paid and collected in accordance with law." The issues to be resolved in the case at bar, as stipulated by the parties, (CTA docket, p .39) are as follows:

DECISION CTA Case No. 5781 Page4 1.) Whether or not petitioner is entitled to a claim for refund of the excess or overpaid income tax for the calendar year ended December 31 , 1996 in the amount of P 6,695,518.00; 2.) Whether or not said excess or overpaid mcome taxes are substantiated by documentary evidence; 3.) Whether or not said excess or overpaid income taxes for the calendar year ended December 31 , 1996 was carried forward to the succeeding taxable calendar year and applied against its income tax liability for the said period; and 4.) Whether or not the said excess or overpaid income tax for the calendar year ended December 31 ,1996 in the amount of P6,695,518.00 was declared as part of the gross income of petitioner. The legal basis relied upon by petitioner in filing a claim for refund is Section 69 (now Section 76) of the National Internal Revenue Code, which provides: "Section 69. Final Adjustment Return. Every corporation liable to tax under Section 24 shall file a final adjustment return covering the total net income for the preceding calendar or fiscal year. If the sum of the quarterly payments made during the said taxable year is not equal to the total tax due on the entire taxable net income of that year the corporation shall either: (a) Pay the excess tax still due; or (b) Be refunded the excess amount paid, as the case may be. In case the corporation is entitled to a refund of the excess estimated quarterly income taxes paid, the refundable amount shown on its final adjustment return mat be credited against the estimated quarterly income tax liabilities for the taxable quarters of the succeeding year." In the case at bar, the alleged overpayment of income tax was brought about by the inadvertence committed by the petitioner in failing to declare the correct amount of

DECISION CTA Case No. 5781 Page5 creditable income taxes withheld in its original income tax return. As can be gleaned from the records of the case, petitioner for taxable year 1996 declared the following in its original annual income tax return (Exhibit A): Taxable Income Pl82,277,704.00 P640.095.737.00 8.952,444.00 P224,033 ,508.00 Tax Due Less: Tax Credits 191,230, 148.00 p 32.803.360.00 Quarterly Payments Creditable Tax Withheld Amount Payable On March 30, 1999, petitioner amended its 1996 income tax return (Exhibit B) to include the amount of P6,695,518.00 as 1996 creditable withholding taxes which were not declared in the original 1996 return. After considering all the taxes withheld, petitioner would only be liable for the lesser income tax of P26,107,842.00, computed as follows: Taxable Income P640.095.737.00 P224,033 ,508.00 Tax Due Pl82,277,704.00 Less: Tax Credits 15,647,962.00 197.925.666.00 p 26.107.842.00 Quarterly Payments Creditable Tax Withheld Amount Payable Hence, petitioner allegedly made an overpayment of P 6,695,518.00, which is being claimed in the instant petition for review, to wit: 1996 Income Tax Paid p 32,803,360.00 Less: Should be payment 26. I07.842.00 1996 Overpaid Income Tax p 6.695.518.00

DECISION CTA Case No. 5781 Page6 However, as oft-cited by this court in a number of similar cases, in order to be entitled to a refund of excess creditable withholding taxes, the petitioner must prove: 1.) That the claim for refund was filed within the two-year prescriptive period provided under Section 204(c) in relation to Section 229 of the Tax Code; 2.) That the fact ofwithholding is established by a copy of a statement duly issued by the payor (withholding agent) to the payee, showing the amount paid and the amount of tax withheld therefrom; and 3). That the income upon which the taxes were withheld were included in the return of the recipient [Section 2.58.3(B) ofRevenue Regulations No. 2-98; Citibank, NA vs. Court of Appeals and CIR, 280 SCRA 459; ACCRA Investments Corporation vs. Court ofAppeals, 204 SCRA 957]. That both the administrative and judicial claims for refund were timely filed is conceded (Stipulated Fact, Item No. 6, CTA Docket p. 38). The written claim for refund filed with respondent's bureau on April 8, 1999 and the Petition for Review filed with this court on April 14, 1999 are both within the two-year period reckoned from the date when petitioner filed its final adjustment return which is April 15, 1997. As to the second requirement, the independent CPA in his report dated June 29, 2000 noted the following (Exhibit KKKKKKK): "We noted a difference between the total amount of EWT base as indicated in the Certificates of Creditable Withholding Tax issued by the Company 's customers and the total amount ofsales for the said customers as recorded in the Company 's books/ITR (See Annex 1): Total Amount ofEWT Base indicated in the Certificate p 1,564, 796,224.00 Total Amount ofSales (for the said customers) per I. 755.310.214.53 Books/ ITR p /90.5/3.990.53 Difference- Sales per Books/ITR is over by

DECISION CTA Case No. 5781 Page 7 We understand that the above difference amounting to P 190,513,990.53 is accountedfor as follows: a. Sales recorded in prior years but collected only in 1996 were subjected to EWT by the customers in 1996 and the corresponding Certificates of Creditable Withholding taxes therefrom were received also in 1996 upon collection, thereby resulting in higher EWT base per Certificates than the amount ofsales per books/ITR in the year 1996; b. Sales recorded in 1996 but still uncollected as ofthe end ofthat year were not yet subjected to EWT by the customers, thereby resulting in higher amount of sales per books!JTR than the EWT base per Certificate. c. In certain cases, adjustments to the sales (e.g. , sales return, sales discounts) by way of credit memos are issued only after collection and receipt of Certificates of Creditable Withholding Taxes. Thus, the total EWT base indicated in the certificates corresponding to the same sale is still gross of adjustments while the total amount ofsales recorded in the books is already net ofthe aforementioned adjustments, thereby, resulting in higher EWT base per certificate than the net sales recorded in the books!JTR. Adjustments to EWT pertaining to the same sale are effected in sales for the subsequent year. Thus, resulting in lower EWT base per Certificate than the net sales recorded in the books!JTR ". While we take note of the foregoing explanation given by the independent auditor on how the difference between the total amount of EWT base as indicated in the certificates of creditable withholding tax issued by the company's customers and the total amount of sales for the said customers as recorded in the company' s books/ITR was arrived at, this court is still not convinced to grant the refund of the full amount claimed. The independent CPA failed to reconcile the difference between the amount declared as

DECISION CTA Case No. 5781 PageS income in the income tax return and the total EWT base as appearing in the certificates. Petitioner likewise failed to present the prior year' s income tax return, which allegedly included the corresponding income of 1996 taxes withheld. As to the second reason advanced by the independent CPA, this court found that only those from FB Ladao Sales and Tire King & Rubber Products have adjustments based on the documents submitted. The rest have none. Thus, we deem it proper to disallow the following creditable taxes withheld corresponding to these income, which cannot be verified to have been declared in the income tax return, to wit: WITHHOLDING AGENT UNDECLARED CORRESPONDING SALES TAX WITHHELD CJ FERNANDEZ ENTRP DURATRAK CORP p 9,135,570.47 p 91 ,355.70 FRANCISCO MOTORS 8 ,136 ,308 .57 81 ,363.09 HERSAN TRDG CORP 892 ,706 .19 PETRONCORP 45 ,293 .61 8,927 .06 TOYOTA MOTORS 10,915,137.12 452 .94 NEW BIAN YEK COMML 677 ,166.4 7 YY &CO. 23 ,189.47 109,151. 37 5 828.79 6,771 .67 231 .89 p 29 831 200 69 p 58.29 29831201 As to the third requirement, the findings of the independent CPA in his report dated May 25, 2000 (Exhibit IIIIIII) are: A. Creditable Withholding Taxes Supported by Certificates of Taxes Withheld Issued for the Year 1995 I. Supported by Original Certificates p 75,061.63 2. Supported by Photocopied Certificates with Original Stamp 1,063,717 . 13 " Received" by Banks

DECISION CTA Case No. 5781 Page9 B. Creditable Withholding Taxes Supported by Original Certificates p 1,138,778.76 8,485 ,870.49 C. Creditable Withholding Taxes Supported by Original Certificates 3,2 13,035.25 without Stamp "Received" by Banks D. Creditable Withholding Taxes Supported by Photocopied 2.810.267.74 Certificates with Original Stamp "Received" by Banks and Stamped "Certified True Copy" and Signed by the Banks TOTAL - Creditable Withholding Taxes per Schedule P l 5 ,647,95 2 .24 Unaccounted difference-passed due to immateriality I 0 .00 TOTAL - Creditable Withholding Taxes per 1996 lncome Tax Return Pl5.647.962.24 However, we do not give evidentiary weight to the photocopied certificates of creditable taxes withheld in the amount of P1 ,063,717.13. Although they bear the original stamp "Received" by banks, we are left in quandary as to why petitioner was able to procure certified true copies of the other certificates but not of these disallowed documents. As we are left in doubt, we are constrained to disallow the photocopied documents that were not compared with their respective originals or were not certified as true and correct. Considering that the success of a claim for tax refund depends on the accuracy of the pertinent documents, we frown upon reception of photocopied documents especially ifthe subject of the inquiry is its very contents. Other than the said observations, we find the findings of the independent CPA to be in order, as petitioner was able to present the various certificates of creditable tax withheld at source to prove the fact of withholding, to wit: CUSTOMER EXHIBIT PERIOD WITHHOLDING COVERED TAX PER CERTIFICATE

DECISION CTA Case No. 5781 Page 10 C.J. FERNANDEZ ENTERPRISE H7-15 Jan-Mar 96 p 288,371 .61 1,200 ,918 .82 H7-35 Apr-96 65,123.1 6 H7-36 May-96 H7-37 Jun-96 158,167.53 H7-59 Jul-96 50 ,852 .75 H7-60 Aug-96 H7-61 Sep-96 121,47 1.81 H7-81 Oct-96 119,878.33 H7-62 Nov-96 107,040 .76 H7-80 Dec-96 93,854.57 Jan-Dec 96 138 ,130 .8 1 58,027.49 p COLUMBIAN AUTOCAR CORP H7-149 12 ,050 .00 COMMERCIAL MOTORS CORP H7- 16 Jan-Mar 96 p 5,291 .87 19 ,932 .67 H7-38 Apr-Jun 96 5 ,227 .07 H7-151 Jui-Sep 96 9,413 .73 DASHER MKTG CORP H7-3 Dec-95 p 75,061 .63 H7-1 7 307 ,946 .57 H7-40 Jan-Mar 96 H7-39 46 ,516 .69 H7-63 Apr-96 97 ,815.88 H7-64 94 ,270 .21 H7-65 May-96 115,069.54 H7-84 87,015.02 H7-85 Jul-96 105,308.54 H7-86 140,274.17 Aug-96 135,140.63 Sep-96 Oct-96 Nov-96 Dec-96 1,204 ,418 .88 DURATRAK CORP H7-20 Jan-Feb 96 p 353 ,014 .15 1,624 ,903 .72 H7- 19 Feb-96 4,146.99 H7-18 Mar-96 H7-41 Apr-96 151 ,808.84 H7-42 121,478.18 H7-82/3 May-Jun 96 143 ,572 .99 H7- 122/3 Jun-96 H7-120/1 73 ,886 .89 Jui-Sep 96 288 ,4 12.96 Oct-Dec96 488 ,582 .72 FB LADAO SALES H7-21 Jan-96 p 90 ,258 .58 H7-22 74 ,688 .86 H7-23 Feb-96 100,315.34 H7-93 76,314.33 H7-94 Mar-96 95 ,052 .35 Apr-96 May-96

DECISION CTA Case No. 5781 Page II H7-95 Jun-96 27,101 .18 853 ,398 .90 H7-87 Jul-96 83,527.09 153,566 .31 H7-88 Aug-96 76 ,849 .53 H7-89 Sep-96 82 ,715.48 207,710.30 H7-90 Oct-96 73 ,127.28 9 ,738 .25 H7-91 Nov-96 44 ,607 .65 225.30 H7-92 Dec-96 28,841 .23 903,174.25 FRANCISCO MOTORS CORP H7-142 Jan-Mar 96 p 41 ,647.78 HERSAN TRDG CORP H7-147 Apr-Jun 96 43 ,724 .15 H7-153 Jui-Sep 96 37 ,971.21 MARCOPPER MINING H7-152 Oct-Dec 96 30 ,223 .17 NEW SIAN YEK COMML NEW CAPITOL TIRE TRDG H7-14 Jan-Mar 96 p 50 ,713 .88 H7-43 Apr-96 19,686 .23 H7-44 May-96 21,454 .66 H7-45 Jun-96 20,224.22 H7-66 Jul-96 17,994.67 H7-67 Aug-96 18,340.56 H7-68 Sep-96 13,519.22 H7-96 Oct-96 17 ,266 .88 H7-97 Nov-96 19,881 .30 H7-98 Dec-96 8 ,628 .68 H7-4 Dec-95 65.97 H7-154 Oct-96 p 49.03 H7-99 110.30 H7-155 Nov-96 117,853 .00 H7-26 Dec-96 93 ,600 .83 H7-25 66 ,235 .94 H7-24 Jan-96 p 37,484.79 H7-46 94,667.37 H7-47 Feb-96 38 ,735 .28 H7-48 60 ,373 .28 H7-69 Mar-96 90 ,217 .86 H7-70 73 ,853.47 H7-71 Apr-96 95,682.40 H7-156 H7- 157 May-96 108,315.47 H7-100/1 26,154.56 Jun-96 Jul-96 Aug-96 Sep-96 Oct-96 Nov-96 Dec-96

DECISION CTA Case No. 5781 Page 12 NISSAN MOTOR PHILS INC H7-49 Jan-Mar 96 P 84,278.42 247 ,657 .33 H7-72 Apr-Jun 96 93,679.63 H7-102 Jui-Sep 96 69 ,699 .28 PETRONCORP H7-27 Jan-96 p 295,948.69 H7-50 1,185.78 PAMCOR H7-29 Jan-96 PILIPINAS HINO H7-28 222 ,427. 24 RICHWELL TRDG CORP H7-5 1 Feb-96 214 ,949 .15 H7-52 258,521 .51 SUN MASSTER SALES CORP H7-53 Mar-96 135,720 .51 H7-73 149,138.01 H7-74 A p r-96 110,029.52 H7-75 224 ,599 .50 H7-103 May-96 208 ,916.96 H7- 104 194,233.09 H7-105 Jun-96 85,020.19 Jul-96 168,069.41 Aug-96 216 ,295 .44 394 ,243 .29 Sep-96 416,605 .49 Oct-96 7,158.63 19 ,676 .03 Nov-96 15,812 .47 20,711 .83 Dec-96 2 ,268 ,759 .56 37 ,819 .69 1,027 ,144.22 H7-5 1995 p 54,01 3. 44 H7-6 64 ,438 .47 63 ,358 .96 H7-7 1995 33 ,280 .53 54 ,389 .7 1 647,498.32 1995 82 ,806 .0 1 24 ,365 .47 H7-8 1995 p 69,754.40 H7-9 71 ,223.47 H7-30 1995 4 8 ,00 1. 06 H7-54 107,406 .07 Jan-Mar 96 83 ,442 .55 Apr-Jun 96 H7- 143 Jan-96 p H7-144 H7-145 Feb-96 H7-55 H7-56 Mar-96 H7-57 H7- 148 Apr-96 H7-76 H7-77 May-96 H7-106 H7-158 Jun-96 Jul-96 Aug-96 Sep-96 Oct-96 Nov-Dec96 H7- 124 Jan-96 p

DECISION CTA Case No. 5781 Page 13 H7-125 Feb-96 116,460.23 880 ,788 .83 H7-126 Mar-96 89,158.46 1,555 ,250.64 H7-127 Apr-96 31 ,1 24.84 H7-128 May-96 91 '131.68 460,687.68 H7-129 Jun-96 90 ,336 .67 44,748.90 H7-130 Jul-96 50 ,174.13 H7-131 Aug-96 91 ,501.93 2 ,143,020 .42 H7-132 Sep-96 72 ,508 .17 118,941 .59 H7-133 Oct-96 57,168.48 58 .29 H7-134 Nov-96 82 ,137.44 H7-135 Dec-96 25 ,644 .25 TIMOG TIREHAUS CORP H7-136 Jan-Mar 96 p 374,768.01 TIRE KING & RUBBER PROD H7-137 Apr-Jun 96 460 ,434 .28 H7-138 Jui-Sep 96 424 ,238 .44 TIREWORLD SALES H7-139 Oct-Dec 96 295 ,809.91 TOYOTA MOTORS UNIVERSAL MOTORS CORP H7-31 Jan-96 p 64,953.65 YY&CO. H7-32 32,741 .44 H?-33 Feb-96 32,303 .90 H7-107 21,503.73 H7-108 Ma r-96 57 ,946.73 H7-109 32,717.82 H7-110 Apr-96 41 ,316.26 H7-111 49,167 .70 H7-112 May-96 30 ,370.02 H7-113 37 ,282 .00 H7-114 Jun-96 48 ,750 .15 H7-115 11 ,634.28 Jul-96 H7- 116 596,185.78 Aug -96 545 ,913 .25 539,011.22 Sep-96 461 ,910.17 Oct-96 22 ,348.66 21 ,726.37 Nov-96 25,529.59 4 9 ,336 .97 Dec-96 Jan-Dec 96 H7-146 Jan-Mar 96 p H7-159 Apr-Jun 96 H7-161/2 Jui-Sep 96 H7-1 63/4 Oct-Dec96 H7-34 Jan-Mar 96 p H7-58 Apr-Jun 96 H7-78 Jui-Sep 96 H7-117 Oct-Dec 96 H7-79 Jui-Sep 96

DECISION CTA Case No. 5781 Page 14 TOTAL TAXES WITHHELD PER CERTIFICATES p 15,647,952.14 Less: Disallowances 1,362.029.14 p 14 285 923 00 (a) Taxes withheld with undeclared income p 298,312.01 (b) Taxes withheld supported by certificates that are not certified true copies 1.063.717.13 TOTAL ALLOWABLE CREDITABLE TAXES WITHHELD As to whether or not the excess creditable withholding taxes were carried over to the succeeding year, we answer in the negative. As shown in 1997 annual income tax return (Exhibits MMMMMMM & MMMMMMM-2) , petitioner left blank the space provided for prior year' s excess credit. Hence, it was clearly shown that petitioner did not utilize the 1996 excess credit of P6,695,518.00 for the succeeding taxable year. In fact, petitioner even incurred a net operating loss. Based on the foregoing, this court is convinced that petitioner is entitled only to the reduced amount ofP 5,333,479.12, computed as follows : 1996 Taxable .Income P640.095.737.00 Tax Due P224,03 3,508.00 Less: Tax Credits P l 8 2 ,277 ,704.12 Quarterly Payments 14,285,923.00 196,563,627. 12 1sl Quarter (Exhibit E-7) P65, I04,702.25 2ndQuarter (Exhibit F-7) 66,012,962.91 3rdQuarter (Exhibit G-7) 51,160,038.96 Creditable Tax Withheld Amount Payable P 27,469,880.88 Less: Amount Paid 32,803,360 .00 Amount Refundable P 5.333.479.12 WHEREFORE, the instant petition for review IS hereby PARTIALLY GRANTED. Accordingly, respondent is hereby ORDERED to REFUND or, in the

DECISION CTA Case No. 5781 Page 15 alternative, ISSUE A TAX CREDIT CERTIFICATE in favor of the petitioner in the reduced amount of P5,333,479.12 representing its overpaid income tax withheld for taxable year 1996. SO ORDERED. ~----~ r Q~ ERNESTO D. ACOSTA Presiding Judge I CONCUR: a_~e.~/~. ~ANITO C. CASTANEDA,~ Associate Judge CERTIFICATION I hereby certify that the above decision was reached after due consultation with the members ofthe Court of Tax Appeals in accordance with Section 13, Article VIII of the Constitution. ~ ~. .~ ERNESTO D. ACOSTA Presiding Judge

DECISION CTA Case No. 5781 Page 16 Annex 1 CUSTOMER EWT EWTBase Sales per Difference-sales per Certificate per Certificate BooksiiTR per BooksiiTR is (A) [(A)/0.01] (Over) Under C.J. FERNANDEZ ENTRP p 1,200,918.82 p 120,091 ,882.00 p 120,859,752 .93 p (767,870.93) - 12,050.00 1,205,000.00 74 ,293 ,742 .76 (73 ,088 ,742 .76) COLUMBIAN AUTOCAR 19,932.67 1,993 ,267 .00 2,551 ' 140.75 (557,873.75) COMML MOTORS CORP 1,204,418 .88 120,441 ,888.00 131 ,565,829.20 (11 ' 123,941 .20) 1,624 ,903 .72 162,490,372.00 158 ,564 , 130. 15 DASHER MKTG CORP 3 ,926 ,241.85 853 ,398 .90 85 ,339 ,890 .00 83,691 ,487.43 1,648 ,402 .57 DURATRAK CORP 153 ,566 .31 15,356,631 .00 14 ,463 ,924 .81 207,710.30 20,771 ,030.00 21 ' 107,469.43 892 ,706 .19 FB LADAO SALES (336,439.43) 9,738.25 973,825.00 100 ,205 ,345 .62 FRANCISCO MOTORS 225.30 22 ,530 .00 37,847,667 .58 973 ,825 .00 22 ,530 .00 HERSAN TRDG CORP 903,174.25 90 ,317 ,425 .00 215 ,960 ,818.88 247 ,657 .33 24 ,765 ,733 .00 186,793 ,253 .56 (9 ,887 ,920 .62) MARCOPPER MINING 2 ,268 ,759 .56 226 ,875 ,956 .00 (13,081 ,934.58) 1,027,144.22 102,714 ,422 .00 10,003,446.10 _J 0,915,137.12 NEW BIAN YEK COMML 68,069,801 .40 (84,078,831 .56) 63,358.96 6,335,896.00 91 ,735,114.69 NEW CAPITOL TIRE 647,498.32 64 ,749 ,832 .00 162 ,0 17 ,898 .70 (3,667,550.1 0) 880 ,788 .83 88 ,078 ,883 .00 43 ,597 ,215 .62 (3 ,319 ,969 .40) NISSAN MOTOR PHILS 1,555 ,250 .74 155 ,525 ,074 .00 (3,656,231 .69) 460 ,687 .68 46 ,068 ,768 .00 4,596,758.92 (6,492 ,824 .70) PETRON CORP 213,624,875.53 44 ,748 .90 4 ,474 ,890 .00 2,471 ,552.38 PAMCOR 2,143,020.42 214 ,302 ,042 .00 13 ,760 ,540 .47 (121 ,868.92) PILIPINAS HINO 119,009.88 11 ,900,988.00 677,166.47 (1 ,859,552.47) RICHWELL TRDG CORP (190,513,990.53) SUN MASSTER SALES TIMOG TIREHAUS CORP TIRE KING & RUBBER TIREWORLD SALES TOYOTA MOTORS UNIVERSAL MOTORS YY &CO. TOTALS p 15,647,962.24 p 1,564,796,224.00 p 1,755,310,214.53 p