UNIOIL PETROLEUM PHILIPPINES, INC. v. COMMISSIONER OF INTERNAL REVENUE

,.. REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Second Division UNIOIL PETROLEUM CTA CASE NO. 11101 PHILIPPINES, INC. Petitioner, Members: RINGPIS-LIBAN, P.J.,Chairperson, MODESTO-SAN PEDRO, and, -versus- FERRER-FLORES, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. ~. : . ) ' '.1 ·' •.J ~ .' lfr f11'l X ---------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Partial Reconsideration (Re: Decision dated 14 January 2026), filed on February 4, 2026, 1 assailing this Court's January 14, 2026 Decision, 2 with Comment/Opposition (to Respondent's Motion for Partial Reconsideration) from petitioner. 3 The Motion lacks merit. Respondent argues that petitioner is not entitled to its claim for refund of alleged erroneously paid excise tax. He insists that Aromatic Hydrocarbon which was imported is subject to excise tax. On the other hand, petitioner counter-argues that the Court has already extensively discussed its exemption from the payment of excise tax. The taxability of aromatic extracts depends on their usage, specifically on lubricating oils and greases, and not on their composition or characteristics. The Court properly declared that since petitioner's imported Aromatic Hydrocarbon VV was not used as lubricating oil or greases, it follows that no 1 Rollo. Ibid. Ibid.

( RESOLliTION CTA CASE NO. 11101 Page 2 of2 excise tax should have been paid on its importation. Thus, the excise tax paid on its importation is refundable. The matters raised by respondent in his Motion for Reconsideration are rehashes of his arguments raised in his submissions to the instant proceedings. Consequently, these have already been addressed and refuted in the Assailed Decision. There is no need to repeat Our discussions by covering these again. 4 No new substantial issues have been raised that would merit the Court En Bane to rule otherwise in his favor. FOR THESE REASONS, respondent's Motion for Partial Reconsideration (Re: Decision dated 14 January 2026) is hereby DENIED for lack of merit. The Decision, dated January 14, 2026, is AFFIRMED. SO ORDERED. MARIA WE CONCUR: ~-~~-- MA. BELEN M. RINGPIS-LIBAN Presiding Justice ~~· s CORApJ~so~iate Justice 4 See Roque v. Commission on Election, G.R. No. 188456 (Resolution). February I 0, 20 I 0; see also Shangri-La International Hotel Management, Ltd. v. Developers Group o.f Companies, Inc., G.R. No. 159938 (Resolution), January 22, 2007; see also Ortigas and Company Limited Partnership v. Velasco, G .R. Nos. 109645 & 112564 (Resolution), March 4, 1996.