SEAN RAPHAEL G. SANTOS v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL SECOND DIVISION SEAN RAPHAEL G. CTA Case No. 12103 SANTOS, 1;fembers: Petitioner, RIN GPIS-LIBAN, Chairperson, -versus - MODESTO-SAN PEDRO, and FERRER-FLORES, Jl COMMISSIONER OF Promulgated: INTERNAL REVENUE, /o.'tJr tftY/ Respondent. X------------------------------------------------------------------------------------ ---X RESOLUTION For resolution is petitioner's Motion for Reconsideration filed on 16 December 2025, seeking reconsideration of the Court's Resolution dated 5 November 2025, which dismissed the Petition for Review for lack of jurisdiction. The Court ruled in the assailed Resolution that the Petition for Review was filed out of time. Consequently, the Court did not acquire jurisdiction over the case. Petitioner now prays for the relaxation of the rules, invoking "compelling humanitarian reasons" and contending that substantive rights would be prejudiced by a rigid application of technicalities. Petitioner avers that his employees would be adversely affected by the dismissal of the present case on mere technicalities. Petitioner's contention is untenable.

RESOLUTION CTA Case No. 12103 The filing of the petition within the period prescribed by law is not a mere technicality but a jurisdictional requirement that cannot be waived or relaxed at will. It is a basic rule that the jurisdiction of a court may be questioned at any stage of the proceedings. 1 More importantly, it is the duty of the courts to first resolve the issue of jurisdiction before delving into other matters in the case, even if the issue is not raised by any of the parties.2 Lack of jurisdiction is one of the recognized exceptions where a case may be dismissed motttproprio at any rime, when it is evident from the pleadings or the evidence on record that such ground exists, even if it was not invoked in the answer or in a motion to dismiss.3 The reason is that jurisdiction is conferred only by law, and the absence thereof affects the very authority of the court to take cognizance of and render judgment in a case.4 Where the court has no jurisdiction over the nature of the action, dismissal is the only recourse. ACCORDINGLY, finding no cogent reason to disturb the earlier ruling, petitioner's Motion for Reconsideration is DENIED for lack of merit. SO ORDERED. ~. ~ , ___ MA. BELEN M. RINGPIS-LIBAN Presiding Justice co~ JiAt6# N G. . FERR~ ER-FL~ OR S Asso�iate jttstice 1 Commissioner ofInternal Revenue v. Mirant Pagbilao Corporation (now TeaM Energy Corporation), G.R. No. 180434, January 20, 2016, 781 SCRA 371; Republic v. Bantigue Point Development Corporation, G.R. No. 162322, March 14, 2012, 668 SCRA 163, 164. 2 Bureau of Customs v. Devanadera, G.R. No. 193253, September 8, 2015, 770 SCRA 24. 3 Section 1, Rule 9 of the Rules of Court; Heirs ofJose Fernando v. De Belen, G.R. No. 186366, July 3, 2013, 700 SCRA 562; Geonzon Vda. De Barrera v. Heirs of Vicente Legaspi, G.R. No. 174346, September 12, 2008, 565 SCRA 192, 198. 4 Bernardo v. Heirs ofEusebio Villegas, G.R. No. 183357, March 15, 2010, 615 SCRA 474-475; Sales v. Barra, G.R. No. 171678, December 10, 2008, 573 SCRA 464.