THE PROVINCE OF NUEVA VIZCAYA and the MUNICIPALITY CASTA?EDA, et al., v. CE CASECNAN WATER & ENERGY CO., INC., NATIONAL IRRIGATION ADMINISTRATION, as the beneficial owner of the Casecnan Project, and CENTRAL BOARD OF ASSESSMENT APPEALS

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC THE PROVINCE OF NUEVA CTA EB NO. 2979 VISCAYA, herein represented by its (CBAA Case Nos. L-60 &74) Honorable Governor ATTY. JOSE V. GAMBITO, RHODA S. MORENO, in her official capacity as the Provincial Members: Treasurer of Nueva Viscaya, ENGR. JOSE L. CARREON,JR., in his official Present: capacity as Provincial Assessor of Ringpis-Liban, P.J., Nueva Viscaya, MUNICIPALITY OF Bacorro-Villena, ALFONSO CASTANEDA, Modesto-San Pedro, represented by its Honorable Mayor Reyes-Fajardo, WILSON M. CAPIA-AO, RODRIGO Cui-David, S. CAYTON, JR., in his capacity as Ferrer-Flores, Municipal Treasurer of Alfonso Angeles, Castaneda and HESPER H. Teston, and VALENZUELA as the Municipal Centeno-Di jamco,]]. Assessor of Alfonso Castaneda, Petitioners- Appellants, -versus- CE CASECNAN WATER & Promulgated: ENERGY CO., INC., NATIONAL IRRIGATION ADMINISTRATION, as the beneficial owner of the Casecnan Project, and CENTRAL BOARD OF ASSESSMENT APPEALS, Respondents-Appellees. X-----------------------------------------------------------------------------------------------X RESOLUTION RINGPIS-LIBAN,y

Page 2 o£4 RESOLUTIO!': CTA EB NO. 2979 For resolution is the petitioner's "Motion for Reconsideration (Re: Decision dated February 12, 2026)"1 flied by registered mail on March 27, 2026, and received by the Court on April 8, 2026, with respondent's "Comment on/Opposition to the Motion for Reconsideration dated March 25, 2026" 2 flied on May 12, 2026. Petitioner seeks reconsideration of the Court En Banis Decision, the dispositive portion of which reads as follows: "ACCORDINGLY, the Petition for Review is DENIED for lack of merit. SO ORDERED." Petitioners-Appellants claim that the Court En Bane erred in affirming the ruling of the Central Board of Assessment Appeals (CBAA) that Petitioners- Appellants are liable to refund the amount computed by the CBAA in favor of respondent CE Casecnan Water & Energy Co. Inc. (CE Casecnan); that the Court En Bane erred in affirming the total amount computed by the CBA.i\ allegedly to be refunded by Petitioner-Appellants; that the Supreme Court's (SC) Decision dated February 1, 2021 did not categorically pronounce that CE Casecnan is entitled to the payment of a refund; that the SC merely remanded the case to the CBAA for the latter to determine the amount to be refunded to CE Casecnan, "if there be any;" and that the Court En Bane erred when it held that there was no grave abuse of discretion on the part of the CBAA in the determination of the refundable amount to CE Casecnan. Meanwhile, Respondents-Appelles assert that the Motion for Reconsideration merely reiterates the arguments that Petitioners-Appellants have already raised in their prior submissions, including their Petition for Review, which have already been considered and correctly resolved by this Court. Moreover, Respondents-Apellees state that the Court En Bane correctly ruled that the CBAA properly proceeded to determine the amount to be refunded to CE Casecnan; that contrary to Petitioners-Appellants' argument, CE Casecnan had a clear right to receive a refund pursuant to the final and immutable SC Decision; that the grant of refund to CE Casescan is automatic, thus, the filing of another written claim for tax refund under the Local Government Code (LGC) would merely require CE Casecnan to relitigate the same issues that were already ruled upon by the Supreme Court in its final and executory SC Decision; that the tax assumption agreement between the National Irrigation Administration (NIA) and CE Casecnan- to which petitioners are not parties- is irrelevant and does not bar the refund of tax payments; that the final and immutable SC Decision clearlv states that CE Casecnan is entitled to a refund ' despite the supposed validity of petitioner's real property tax (RPT) assessments; that the Commission on Audit's (COA) consent and approval are not requiry 1 Rollo, CTA EB l'iO. 2979, pp. 551-561. 2 Ibid., pp. 568-586.

RESOLUTION CTA EB l\:0. 2979 before petitioners may refund the RPTs to CE Casecnan; and that the CBAA correctly interpreted Executive Order (EO) No. 173 and properly computed the RPT amount refundable to CE Casecnan. After consideration, the Court En Bane resolves to deny the "Motion for Reconsideration (Re: Decision dated February 12, 2026)." The Court En Bane reviewed the grounds relied upon by Petitioners-Appellants in support of their Motion for Reconsideration but finds no cogent reason to grant the same. The Court En Bane notes that Petitioners-Appellants basically rehashed their arguments which were sufficiently passed upon and discussed by the Court En Bane in the assailed Decision, to discuss them anew would only be superfluous. Applying the ruling of the Supreme Court in the case of SocialJustice Society (S]S) Officers, et al. v. Alfredo S. Lim, et seq., 3 it would be a useless formality for the Court En Bane to reiterate the reasons already set forth in the assailed Decision, it suffices for the Court En Bane to deal generally and summarily with the motion for reconsideration and merely state a legal ground for its denial, thus: "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, v;:ith respect to issues raised for the first time, these being, 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); z~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." (Emphasis added) In view of the foregoing disquisitions, the Court En Bane finds no compelling reason to reverse or modify the Decision promulgated on February 12, 2026. ACCORDINGLY, the "Motion for Reconsideration (Re: Decision dated February 12, 2026)" is DENIED for lack of me~ G.R. No. 187836, March 10, 2015 (Resolution on .i\.fotion for Reconsideration), citing Ortigas and Compa'!)' limited Partnership v. Judge Tirso Velasco, eta/., eZ seq., G.R );o. 109645, i>.larch 4, 1996 (324 PhiL 483).

RESOLUTIO'i CT/, EB NO. 2979 SO ORDERED. ~. ~ I........._____ MA. BELEN M. RINGPIS-LIBAN Presiding Justice WE CONCUR: /,As 01=iate Justice ./ )~·.·I' Yn· rr. · ~) .. /-·- MARIA RO)VE~~~:m STO-SAN PEDRO · Ass~ate J stlce ~ ~ r. ~ ~ FOj'vrt~ MARIAN IV#. REYES-FAJARDO Associate Justice LAN~~~DAssociate Justice HENR~GELES Associate Justice DEBBIEJE NO-DIJAMCO