BELLAGIO ONE CONDOMINIUM ASSOCIATION, INC., BELLAGIO TWO CONDOMINIUM ASSOCIATION, INC., FORBESWOOD HEIGHTS CONDOMINIUM ASSOCIATION, FORBESWOOD PARKLANE CONDOMINIUM ASSOCIATION, INC., UPTOWN RITZ RESIDENCE CONDOMINIUM ASSOCIATION, INC. v. THE CITY TREASURER OF TAGUIG CITY, MR. VOLTAIRE L. ENRIQUEZ, AND THE CITY GOVERNMENT OF TAGUIG CITY, REPRESENTED BY HON. MAYOR LINO CAYETANO

CTA Form No.8 (For DCC) llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll 22-000539-0022 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA AC NO. 277 BELLAGIO ONE CONDOMINIUM ASSOCIATION, BELLAGIO TWO CONDOMINIUM ASSOCIATION, INC., FORBESWOOD HEIGHTS CONDOMINIUM ASSOCIATION, FORBESWOODPARKLANE CONDOMINIUM ASSOCIATION, INC., UPTOWN RITZ RESIDENCE CONDOMINIUM ASSOCIATION, INC., Pet1.t1. oners, NOTICE OF RESOLUTION -versus- THE CITY TREASURER OF TAGUIG CITY, MR. VOLTAIRE L. ENRIQUEZ AND THE CITY GOVERNMENT OF TAGUIG CITY, REPRESENTED BY HON. MAYOR LINO CAYETANO, Respondents. To: BELLO VALDEZ & FERNANDEZ JGLAW 17th Floor, Robinsons Equitable Tower 4 ADB Avenue comer P. Poveda Drive Ortigas Center, Pasig City ATTY. FATIMA ALCONCEL-RELENTE ATTY. MICELENE C. MALASA City Legal Office 4th Floor, Taguig City Hall Gen. A. Luna Street, Barangay Tuktukan 1637 Taguig City CITY GOVERNMENT OF TAGUIG Taguig City Hall, Gen. A. Luna Street Taguig City MR. VOLTAIRE L. ENRIQUEZ City Treasurer ofTaguig City Office of the City Treasurer Taguig City Hall, Gen. A. Luna Street Taguig City ATTY. JOHN PAUL Z. NANIT Clerk of Court V REGIONAL TRIAL COURT Branch 271, Taguig City 2nd Floor, Hall of Justice, DPWH Compound General Santos Avenue, Upper Bicutan Taguig City, Metro Manila Page 1 of2

GREETINGS: You are hereby notified by these presents that on November 5, 2024, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, November 6, 2024. '< AttyE. MxeacuritaivJeo~ ~o. uCrthIaIn-Te Page 2 of2

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION BELLAGIO ONE CTA AC No. 277 CONDOMINIUM Members: ASSOCIATON, INC., DEL ROSARIO, P.L Chairperson, BELLAGIO TWO MANAHAN, and CONDOMINIUM REYES-FAJARDO J1 ASSOCIATION, INC., FORBESWOOD HEIGHTS CONDOMINIUM ASSOCIATION, FORBESWOOD PARKLANE CONDOMINIUM ASSOCIATION, INC., UPTOWN RITZ RESIDENCE CONDOMINIUM ASSOCIATION, INC., Petitioners, -versus- THE CITY TREASURER OF TAGUIG CITY, MR. VOLTAIRE L. ENRIQUEZ, AND THE CITY GOVERNMENT OF TAGUIG CITY REPRESENTED BY HON. MAYOR LINO CAYETANO, Respondents. Promulgated:

RESOLUTION CTAACNo.277 RESOLUTION REYES-FAJARDO, J.: For resolution are the following: 1. Petitioners' Motion for Partial Reconsideration (of the Decision dated 18 April 2024) filed on May 9, 2024, with respondents' Comment/Opposition to Petitioners' Motion for Partial Reconsideration (of the Decision dated 18 April 2024) filed via registered mail on July 1, 2024, and received by the Court on July 8, 2024; and, 2. Respondents' Motion for Partial Reconsideration (of the Honorable Court's Decision dated 18 April 2024) filed via registered mail on May 14, 2024 and received by the Court on May 22, 2024 with petitioners' Comment and Opposition filed on July 1, 2024 and received by the Court on June 25, 2024. On April 18, 2024, the Court promulgated a Decision (assailed Decision),1 disposing the case as follows: WHEREFORE, the Court RESOLVES to: 1. PARTIALLY GRANT the Petition for Review (under Rule 4, Section 3 of the Revised Rules of the Court of Tax Appeals), filed by Bellagio One Condominium Association, Inc., Bellagio Two Condominium Association, Inc., Forbeswood Heights Condominium Association, Inc., Forbeswood Parklane Condominium Association, Inc. and Uptown Ritz Residence Condominium Association, Inc. 2. AFFIRM the assailed Orders dated September 1, 2022 and October 3, 2022, both rendered by the Regional Trial Court, Branch 271 of Taguig City in Civil Case No. 826, only with respect to the refund claims pertaining to Local Business Tax for 2020 is concerned. Docket, pp. 240 to 262.

RESOLUTION CTA AC No. 277 3. REVERSE the assailed Orders dated September 1, 2022 and October 3, 2022, both rendered by the Regional Trial Court, Branch 271 of Taguig City in Civil Case No. 826, only with respect to the refund claims pertaining to Local Business Tax for 2021 is concerned. 4. REMAND the case to the Regional Trial Court, Branch 271 of Taguig City in Civil Case No. 826, for further proceedings on the merits of the refund claims pertaining to Local Business Tax for 2021. 5. DISMISS the case insofar as petitioners' claims for refund pertaining to environmental impact fee, and business plate/ sticker fee for 2020 and 2021 are concerned, for lack of jurisdiction. SO ORDERED. The Court held that the Court's jurisdiction is confined only to the Regional Trial Court of Taguig, Branch 271 of Taguig City (RTC- Taguig)'s final action on a local tax case. Specifically, the assailed Orders of RIC-Taguig with respect to local business taxes (LBT) is subject of the Court's jurisdiction because it is a local tax. On the contrary, the Court ruled that the environmental impact fees and business plate/ sticker fees are not local taxes; thus, the Court lacks jurisdiction over the same, pursuant to Section 7 (a)(3) of Republic Act (RA) No. 1125, as amended by RA No. 9282. The Court explained that the dismissal made by RIC-Taguig on respondents' Motion to Dismiss was not proper for the following reasbns: First, the Billing Statements issued by respondent City Treasurer of Taguig are not notices of assessments within the contemplation of Section 195 of the Local Government Code (LGC); and Second, petitioners' correctly filed for an administrative and judicial claim for refund of LBT paid for 2021 within the two (2)-year period, pursuant to Section 196 of the LGC; hence, the Court's directive to remand the case to the RIC-Taguig for the determination of the merits thereof is limited to petitioners' refund claim for LBT paid for 2021.

RESOLUTION CTA AC No. 277 Both aggrieved, petitioners and respondents, respectively moved for partial reconsideration of the assailed Decision. Petitioners' Motion for Partial Reconsideration Petitioners assert that the environmental impact fee and business plate/ sticker fee for 2021 may be taken cognizance of by the Court and be joined in one appeal to avoid a multiplicity of suits. They further point out that the Court may relax the strict application of the rules to promote justice in the instant case. Through its Comment, respondents echo the ruling of the Court that it may not address controversies pertaining to environmental impact fee and business plate/ sticker fees which are not local taxes, for lack of jurisdiction. Respondents' Motion for Partial Reconsideration Respondents again maintain that the Billing Statements issued against petitioners are notices of assessment which stated the facts and nature of the taxes assessed as commanded by Section 195 of the LGC. Consequently, said billing statements became conclusive and unappealable because petitioners' claims for refund were filed beyond the period of sixty (60) days from receipt of said billing statements. Petitioners counter that their claims for refund of the LBT assessed for the year 2021 were timely filed within the two (2)-year prescriptive period specified in Section 196 of the LGC. THE COURT'S RULING Both Motions must fail.

RESOLUTION CTAACNo.277 The arguments raised by the parties save for petitioners' contention on joinder of actions were already passed upon by the Court and found wanting in the assailed Decision. In particular, the Court already discussed that its jurisdiction is confined only to the RTC-Taguig's final action pertaining to LBT for 2021 because it is a local tax. There is no need to reiterate pertinent portions of the Decision, or re-write the ponencia in accordance with the outline of the instant motion.2 The pronouncement in Social Justice Society (SJS) Officers, et al. v. Lim3 on the effect and disposition of a motion for reconsideration is instructive: The filing of a motion for reconsideration, authorized by Rule 52 of the Rules of Court, does not impose on the Court the obligation to deal individually and specifically with the grounds relied upon therefor, in much the same way that the Court does in its judgment or final order as regards the issues raised and submitted for decision. This would be a useless formality or ritual invariably involving merely a reiteration of the reasons already set forth in the judgment or final order for rejecting the arguments advanced by the movant; and it would be a needless act, too, with respect to issues raised for the first time, these being, as above stated, deemed waived because not asserted at the first opportunity. It suffices for the Court to deal generally and summarily with the motion for reconsideration, and merely state a legal ground for its denial (Sec. 14, Art. VIII, Constitution); i.e., the motion contains merely a reiteration or rehash of arguments already submitted to and pronounced without merit by the Court in its judgment, or the basic issues have already been passed upon, or the motion discloses no substantial argument or cogent reason to warrant reconsideration or modification of the judgment or final order; or the arguments in the motion are too unsubstantial to require consideration, etc. Anent petitioners' assertion that the issue on its liability for environmental impact fees and business plate/sticker fees for 2020 and 2021 involved a single cause of action and should not be 2 See Social Justice Society (SJS) Officers, eta/. v. Lim, G.R Nos. 187836 & 187916, March 10, 2015. 3 I d.

RESOLUTION CTA AC No. 277 dismissed for lack of jurisdiction. Sps. Victor Milagros Perez and Cristina Agraviador Aviso v. Antonio Hermano4 confirmed: While joinder of causes of action is largely left to the option of a party litigant, Section 5, Rule 2 of the 1997 Rules on Civil Procedure, as amended allows causes of action to be joined in one complaint conditioned upon the following requisites: (a) it will not violate the rules on jurisdiction, venue and joinder of parties; and (b) the causes of action arise out of the same contract, transaction or relation between the parties, or are for demands for money or are of the same nature and character.5 Based on the foregoing, the Court finds no reason to reverse the assailed Decision. WHEREFORE, the parties' respective Motions for Partial Reconsideration of the Decision promulgated on April 18, 2024 are DENIED for lack of merit. ~~f."~-~~ MARIAN IV'f F. REY~S-FAJA"RDO Associate Justice WE CONCUR: (With due respect, I reiterate my Con urring an Dissenting Opinion) ROMAN G. DEL ROSARIO Presiding Justice /~. ~-~ CATHERINE T. MANAHAN Associate Justice 4 G.R. No. 147417, july 8, 2005 5 Boldfacing supplied.