PETRON CORPORATION v. COMMISSIONER OF INTERNAL REVENUE (Consolidated with CTA Case No. 10297)

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Second Division PETRON CORPORATION, CTA CASE NOS.10252 & 10297 Petitioner, Members: -versus- RINGPIS-LIBAN, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JJ COMMISSIONER OF Promulgated: INTERNAL REVENUE, NOV 1 1 2021. Respondent. X -------------------------------------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Reconsideration (Re: Decision promulgated 14 August 2024), filed on September 4, 2024, with petitioner's Opposition (To: Motion for Reconsideration dated 29 August 2024), filed on September 30, 2024. The Motion is completely without merit. It does not escape the Court's notice that the "discussion" in the Motion amounts to simply quoting a lengthy passage from Petron Corporation v. Commissioner ofinternal Revenue1 and a portion of a separate opinion penned by Honorable Associate Justice Erlinda P. Uy.2 Respondent, however, adds nothing to these lengthy quotations, writing a grand total of two original statements in the Motion. He does not explain the relevance of the quotes. He does not discuss what specific points raised in these quotations are applicable to the case at bar. He does not identify which of said points refute the specific reasons given by the Court for Our ruling in the assailed Decision, dated August 14, 2024. He does not show why a Decision rendered by the Court of Tax Appeals should prevail over the Supreme Court's ruling in Petron CTA EB No. 2425 , June 28, 2022. Respondent does not even bother to specify for which case this separate opinion was penned. Notably, Honorable Justice Erlinda P. Uy was the ponente in the quoted Petron case, so the quoted dissent is logically not from there.

RESOLUTION CTA CASE NOS. 10252 & 10297 .� Page 2of2 Corporation v. Commissioner ofInternal Revenue,3 which served as a major basis for Our grant of the Petition for Review. In short, the present Motion is completely lacking in substance, bordering on disrespect for this Court and its procedures. It thus offers Us no reason to reverse Our ruling. ACCORDINGLY, respondent' s Motion for Reconsideration (Re: Decision promulgated 14 August 2024) is hereby DENIED for lack of merit. The Decision, dated August 14, 2024, is hereby AFFIRMED. SO ORDERED. MARIARO WE CONCUR: ~ ~ -v' '---- MA. BELEN M. RINGPIS-LIBAN Associate Justice RES G.R. No. 255961 , March 20,2023.