PEOPLE OF THE PHILIPPINES v. SERAFIN PANALIGAN VILLALOBOS proprietor of PSPV COMMERCIAL RICE SUPPLY & GROCERY, (1637 Dagonoy Street, San Andres Bukid, Santa Ana, Manila) (At-Large)

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SECOND DIVISION PEOPLE OF THE Plaintiff, CTA CRIM. CASE NO. 0-917 PHILIPPINES, For: Violation of Section 255 in - verstts- relation to Sections 253 and 256 of RA 8424, as amended (Willful Failure to Pay Tax) Members: RINGPIS-LIBAN, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JL SERAFIN PANALIGAN VILLALOBOS, proprietor of PSPV COMMERCIAL RICE SUPPLY & Promulgated: xG--R--O--C--E-R--Y--,-----------------------------~~~~~~~-------;-j�-.P-P. .--�'0-!R-. -J1-.0'-7!,v~.::,~~---------------x Lf�. 'h. f'n. RESOLUTION RIN GPIS-LIBAN, L;. For resolution of the Court is the plaintiffs Motion for Reconsideration (Re: Decision dated 26 November 2024/ (the "Motion") flied on December 9, 2024. The accused failed to ftle his comment to the Motion despite this Court's order to ftle the same issued on December 13, 2024 as per the Records Verification Report submitted by this Court's Judicial Records Division dated March 11, 2025. Plaintiffs lv!otion seeks reconsideration of this Court's Decision promulgated on November 26, 2024, ("Assailed Decision") acquitting the 1 Docket, pp. 372-403.

RESOLUTION CTA Crim. Case No. 0-917 accused of the crime charged. The dispositive portion of the Assailed Decision reads: "WHEREFORE, premises considered, accused Serafin Panaligan Villalobos is ACQUITTED of the crime charged. The cash bail bond posted by the accused for his provisional liberty in the amount of Sixty Thousand Pesos (P60,000.00) is DISCHARGED and to be RELEASED to him upon presentation of proper documents, in accordance with the usual accounting rules and regulations. SO ORDERED." In its Motion, plaintiff insists that this Court erred in ruling that the plaintiff failed to adduce sufficient evidence to convict the accused. While it submits that its witness admitted during her testimony that the subject BIR correspondences were not served personally to the accused, they were received by a person known to the accused. It added that the accused admitted during cross-examination that he was already in possession of these documents only that he cannot remember the time of receipt. After careful evaluation of the arguments raised by the plaintiff vis-a-vis the records of the case, the Court resolves to deny plaintiff's Motion for lack of merit. Plaintiff failed to raise any compelling reason to warrant the modification much less reversal of this Court's findings. The Court maintains its position that the accused must be acquitted for failure of the plaintiff to prove all the elements of the offense charged and that none of the pieces of evidence presented by the plaintiff, whether testimonial and/ or documentary, sufficiendy serves as competent evidence of the accused's civil liability for taxes. WHEREFORE, the plaintiffs Motion for Reconsideration (Re: Decision dated 26 November 2024) is DENIED for lack of merit. SO ORDERED. ~. ~ __, '---- MA. BELEN M. RINGPIS-LIBAN Associate Justice

RESOLUTION CTA Crim. Case No. 0-917 IVE CONCUR: MARIA ROWENA MODESTO-SAN PEDRO Associate Jusrice CO~Rf!~!P~dG~."-FE tR1~ fS Associate Jusrice .