RICHARD MALABANAN MANGUBAT v. BUREAU OF INTERNAL REVENUE REGION NO. 8B (SOUTH NCR) represented herein by its Regional Director, ATTY. JETHRO M. SABARIAGA

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Second Division RICHARD MALABANAN CTA CASE NO. 11063 MANGUBAT, Petitioner, Members: -versus- RINGPIS-LIBAN, PJ, Chairperson, MODESTO-SAN PEDRO, and BUREAU OF INTERNAL FERRER-FLORES, JJ REVENUE- REVENUE REGION NO. 8B (SOUTH NCR) represented herein by its Regional Promulgated: Director, ATTY. JETHRO M. 9! ].-() !Jif SABRIAGA, Respondent. X -------------------------------------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration, filed via licensed courier on March 2, 2026, without any comment from respondent, 1 assailing this Court's February 3, 2026 Decision. The motion lacks merit. To recall, We dismissed this case for lack of jurisdiction as petitioner failed to timely file his protest against respondent Formal Letter of Demand and Final Assessment Notice ("FLD/FAN"). Petitioner's present motion, however, does not address this. He does not offer a reason for the late filing or even relate the arguments he raises in the motion to that central issue. Further, said arguments are rehashed from his previous pleadings and have already been considered by this Court in the assailed Decision. There is consequently no need to address them in detail here.2T See Records Verification, dated May II, 2026, Rollo Vol. 2, unpaginated. See Roque v. Commission on Election, G.R. No. 188456 (Resolution), February I0, 20 I0; see also Shangri-La International Hotel Management, Ltd. v. Developers Group ofCompanies, Inc., G.R. No. 159938 (Resolution), January 22, 2007; see also Ortigas and Company Limited Partnership v. Velasco, G.R. Nos. I09645 & 112564 (Resolution), March 4, 1996.

- ., RESOLliTIO~ CTA CASE NO. II 063 Page 2 of2 As the points raised are merely repeated from his Petition and Memorandum, and as petitioner fails to directly address the primary reason for the dismissal of his case, petitioner fails to convince Us to reverse Our previous ruling. FOR THESE REASONS, petitioner's Motion for Reconsideration, filed via licensed courier on March 2, 2026, is hereby DENIED for lack of merit. SO ORDERED. I l r'iI --=- nEsTo-sAN PEDRO WE CONCUR: i..t. ~ ~ '--- MA. BELEN M. RINGPIS-LIBAN Presiding Justice