CASAS + ARCHITECTS, v. COMMISSIONER OF INTERNAL REVENUE

H.EPUBLIC OF THE PHILII>PINES Court of Tax Appeals QUEZON CITY Third Division CASAS+ ARCHITECTS, CT A CASE NO. 9705 Petitioner, Members: -versus- UY, Chairperson, RINGPIS-LIBAN, and MODESTO -SAN PEDRO, JJ. COMMISSIONER OF INTERNAL Promulgated: R EVENUE, Respondent. X -------------------------------------------------- ~--~-------(-c-:-t-7-g---~-�-- ---.------------ X RESOL U TIO N For reso lution is respondent' s M otion for Reconside ratio n (on the Resolution promulgated on 16 September 201 9) filed through registered mail on 8 October 2019, and received by this Court on 15 October 20 19 1 ("Motion for Reconsideration"), with petitioner's Comment (R e: Motio n for Reconsidera tion da ted 7 October 2019), filed through registered mail on 6 November 2019, and recei ved by this Court on 13 November 20192 ("Comment"). In the Motion for Reconsideration, respondent al leges that when he filed his Formal Offer of Evidence on 7 August 20 19, it was on the assumption that a comparison of his documentary exhibits had already been done at a Commissioner's Hearing scheduled for that purpose; that he only learned of the non-marking of Exhibits "R-1 ", "R-1-a"' "R-2"' " R-2-a"' "R- 3re"c'e"iRve-d3-tah"i's"CRo-u4t"1''"sRR-5es"o' l"uRti-o5n-ad"a't"edR-166" "R-7" "R-8" and "R-9" when he 'Septem'ber 20 1' 9; that the fai lure of respondent's counsel to mark and compare hi s evidence is solely due to heavy pressure of work; and that respondent's counsel had no intention to delay the proceedings in this case. Respondent prays that this Court allow one (1) Commissioner's Hearing be scheduled for the purpose of marking and comparing the aforesaid Exhibits. In the Comment, petitioner counters that the Motion for Reconsideration should be di smissed outright as it docs not contain a Notice Docket, Vo l. 4, pp. l 648- 165 1. Docket, Vo l. 4.

RESOLUTION CT A CASE NO. 9705 of Hearing; and that respondent was already given sufficient opportunity to mark and compare his documentary exhibits. The Motion for Reconsideration lacks merit. In a plethora of cases, the Supreme Court held that a lawyer's heavy workload is insufficient reason to justifY the relaxation of procedural rules.3 After all, heavy work load is relative and often self-serving.4 As such, this Court cannot save respondent from a peril caused by his own negligence; that is, the failure of respondent's counsel to properly go about with his affairs with this Court. Further, this Court does not believe respondent's contention that he only learned of the non-marking of Exhibits "R-1", "R-1-a", "R-2", "R-2-a", "wRh-e3n"'he"Rre-c3e-iav"e' d"tRhe-' 4R"e"sRo' -lu5t"ion"Rda-5te-da"' 16"SRe-p6' t"em"bRe-r' 72"019"R.' -A8s" boarnnde "R-9" by the records, respondent manifested during the Commissioner's Hearing held on 19 June 2018 that he has no documents to mark. Such argument seem to be respondent's afterthought after his counsels failed to prepare the documents, which he will offer as evidence in this case, for comparison during the scheduled Commissioner's Hearing. While the Court recognizes the heavy workload of respondent's counsels, the same cannot be constantly and conveniently used as an excuse for failure to comply with court procedure. Legal technicalities are put in place for effective and efficient administration of justice. It should not be carelessly set aside since it is for the benefit of the litigants to begin with. WHEREFORE, m light of the foregoing considerations, respondent's Motion for Reconsideration (on the Resolution promulgated on 16 September 2019) is DENIED for lack of merit. SO ORDERED. ER~P.UY Associate Justice Cesar Naguit v. San Mignel Corporation, G.R. No. 188839, 22 June 2015, citing Mid-Islands Power Generation Corporation v. Court of Appeals, G.R. No. 189191, 29 February 2012, 667 SCRA 342, 355. ld, citing Laguna Metts Corporation v. Court ofAppeals, G.R. No. 185220, 27 July 2009.

RESOLUTION CTA CASE NO. 9705 (On Leave) MA. BELEN M. RINGPIS-LIBAN Associate Justice