COMMISSIONER OF INTERNAL REVENUE v. NATIONWIDE HEALTH SYSTEMS BAGUIO, INC.

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 2264 REVENUE, (CTA Case No. 9507) Petitioner, Present: -versus- DEL ROSARIO, P.J., RINGPIS-LIBAN, MANAHAN, BACORRO-VILLENA, MODESTO-SAN PEDRO, REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and ANGELES,JJ NATIONWIDE HEALTH SYSTEMS Promulgated: BAGUIO, INC., OCT 3 0 2024 Respondent. X ---------------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration, filed on April 1, 2024, without any comment from respondent. 1 Petitioner assails this Court's Resolution, dated March 6, 2024 ("assailed Resolution"), which denied his Petition for Relief from Judgment for lack of merit and for being filed late. The arguments raised in the Motion are almost a complete rehash of those in petitioner's Petition for Relief of Judgment, which itself rehashed arguments petitioner had previously raised. As such, the Motion must be denied. Importantly, petitioner still insists that he only learned of the Decision, dated December 9, 2021, on July 7, 2022, when he received a copy of the Entry of Judgment for this case. This, however, is patently false. As observed/ See Records Veri fication , dated August 6, 2024, Rollo, unpaginated.

RESOU TIO'\ CTA EB '\JO. 226-t (CTA Case No. 9507) Page 2 of3 in the assailed Resolution, the Office the Solicitor General, petitioner's counsel in this case, had already filed a Compliance on February 18, 2022, stating that it received the subject Decision on December 21, 2021. As notice to counsel is equivalent to notice to the party represented," petitioner is deemed to have been apprised of the adverse ruling on December 21, 2021, hence Our finding that the Petition for Relief from Judgment was filed late. As for the other points raised by petitioner, these merely repeat what he has raised in previous pleadings, all of which have already been refuted by this Court across Our previous issuances. They consequently deserve scant consideration and need not be addressed for the n'11 time.3 ACCORDINGLY, petitioner's Motion for Reconsideration, filed on April I, 2024, is hereby DENIED for lack of merit. The Resolution, dated March 6, 2024, is hereby AFFIRMED. SO ORDERED. Associate Justice WE CONCUR: Presiding Justice L ~ -"7''-- MA. BELEN M. RINGPIS-LIBAN Associate Justice � 7. ~ 4:..4'~�""0.u.. )tt._.-- CATHERINE T. MANAHAN Associate Justice See Philippine National Bank v. Sps. I"ictar. G.R. No. 207377. July 27. 2022: see also Puregold Price Club. Inc. v. Court o(Appeals, G.R. No. 244374. February 15.2022. See Roque v. Commission on Election, G.R. No. 188456 (Resolution), February I0, 20 I0; see also Shangri-La International Hotel Afanagement. Lrd. \'. Det�e!opers Croup q{Companies, Inc., G.R. No. 159938 (Resolution). January 22. 2007: see a/.<m Ortigas and Company Limited Partnership v. l"elasco, G.R. Nos. 109645 & 112564 (Resolution). March 4. 1996. - - - - - - - - - - - - - - - - - - - - - - - - - - - ---- --

RESOUTIO'i CTA E8 NO. 226-l- {CT/\ Case :.Jo. 9507) Page 3 of3 A~ ~ J; ~ -r(f�~ MARIAN IVV'F. REYif'S-FAJARDO Associate Justice ~4~ LANEE S. CUI-DAVID Associate Justice c~ ~ ..t.:c..('(. C.3~Q Associate Justice ON lEAVE HENRYS. ANGELES Associate Justice