BUREAU OF INTERNAL REVENUE v. HON. MENARDO I. GUEVARRA in his capacity as SECRETARY OF JUSTICE and MYRA EVANGELISTA SANTIAGO

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane BUREAU OF INTERNAL REVENUE, CTA EB NO. 2381 Petitioner, (CTA Case No. 10101) Present: DEL ROSARIO , P.J., -versus- CASTANEDA, JR., UY, RI NG PIS -LIBA N , MANAHAN, BACORRO-VILLENA, and HON. MENARDO I. GUEVARRA, in MODESTO-SAN PEDRO, JJ his capacity as SECRETARY OF JUSTICE and MYRA EVANGELISTA Promulgated: SXA--N---T---I-A---G---O---,----------------------------~:~!:_~-~-~~~::~-------F--E---B-----0---3----2-0-t2.1!)//)�___:_�_~~ . RE S OLUTION For the Court's resolution are (a) respondent Myra Evangelista Santiago's "Comment/Opposition [Re: Petition for Review dated 17 November 2020]" ("Comment"), fi led via registered mail on 14 December 2020, (b) petitioner's "Compliance," filed on 15 January 2021, and (c) petitioner's Petition for Review, filed on 24 November 2020. Acting on respondent's "Comment," the same is hereby NOTED . Meanwhile, the Court notes that the Notice of Resolution attached to respondent's "Compliance" is, once more, a mere photocopy. The Court further notes that, while said photocopy bears a stamp marking the Notice of Resolution as having been received on 29 October 2020, the photocopy of the same Notice of Resolution attached to petitioner's Petition for Review bears a stamp marking it as having been received on 13 October 2020. The instant Petition, however, was fi led on 24 November 2020. Thus, even if petitioner received the assailed Resolution on 29 October 2020, and regardless of when this case was assigned to its counsel, petitioner had fifteen (15) days from receipt of the assailed Resolution, or until 13 November 2020, within which to file its Petition for Review before the Court En Bane. The instant Petition was therefore filed out of time.

RESOLUTION CTA �8 NO 2381 (CTA Case No. 10101) Page 2 of2 WHEREFORE, the instant Petition for Review is hereby DISMISSED for being filed out of time. SO ORDERED. Presiding Justice ~~c.ar~...~Sl-. JlfANITO C. CASTANEuK, JR. Associate Justice ER~P.UY Associate Justice ~- ~ AL_ MA. BELEN M. RINGPIS-LIBAN Associate Justice ch~~~~ - Associate Justice ~ JEAN !V.LAKH)I MARIA u-;:,Al'lj PEDRO