OFFICE OF THE CITY TREASURER AND/OR MAKATI CITY v. SOUTH CHINA RESOURCES, INC. (NOW KNOWN AS `SOCRESOURCES, INC.)

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC OFFICE OF THE CITY TREASURER CTA EB NO. 2154 AND/OR MAKATI CITY, (CTA AC NO. 197) Petitioner, -versus- Present: Del Rosario, P.J., Castaneda, Jr., Uy, Ringpis-Liban, Manahan, Bacorro-Villena, and Modesto-San Pedro, ]]. SOUTH CHINA RESOURCES, INC. Promulgated: (NOW KNOWN AS "SOCRESOURCES, INC."), - ---R---e-J-p--o-n--d-e-n--t.----------------- JUL 1 52021 � ~~ X--------------------------------- -------------------------~--~~~Jf), RESOLUTION RINGPIS-LIBAN, J.: For resolution is the petitioner's "11o tion for Reconsideration"1 ftled on January 20, 2021. In the instant motion, petitioner avers that the decision of the Court E n Bane is a direct attack to the local auto no my of the City of Makati and a collateral attack to the Revised Makati Revenue Code; and that the Court En Bane erred in holding th at the imposition of local business tax o n respondent falls within Section 133(a) of the Local Government Cody 1 Docket. CTA EB NO. 2154, pp. 93-1 01 .

Resolution CTA EB NO. 2154 (CTA AC NO. 197) On February 4, 2021, respondent filed its "Opposition (To Petitioners' Motion for Reconsideration" dated 20 January 2021)." After consideration of the motion submitted, the Court En Bane resolves to deny the "Motion for Reconsideration." The Court En Bane notes that petitioner's motion merely reiterates or amplifies the arguments previously raised in the Petition for Review which were already considered and extensively discussed upon by the Court En Bane in the assailed Decision. In the case of Shangri-La International Hotel Management Ltd, et aL vs. Developers Group of Companies, Im:,Z the Supreme Court denied respondent's Motion for Reconsideration for being a mere reiteration of their previous arguments, and for failure to raise matters substantially plausible or compellingly persuasive to warrant the reversal of the assailed Decision, thus: "The bulk of the aforementioned grounds is a mere rehash of movant's previous arguments. While DGCI is correct in stating that a motion for reconsideration, by its very nature, may tend to dwell on issues already resolved in the decision sought to be reconsidered and that this should not be an obstacle for a reconsideration, the hard reality is that movant has failed to raise matters substantially plausible or compellingly persuasive to warrant the desired course of action. Considering that the grounds presently raised have been sufficiently considered, if not squarely addressed, in the subject Decision, it behooves movant to convince the Court that certain findings or conclusions in the Decision are contrary to law. As it is, however, the instant motion does not raise any new or substantial legitimate ground or reason to justify the reconsideration sought." In view of the foregoing, the Court En Bane will no longer belabor to repeat its discussions in the assailed Decision since it would only result to mere superfluity. WHEREFORE, premises considered, the petitioner's "Motion for Reconsideration" is DENIED for lack of merit. ~ 2 G.R. No. 159938, January 22. 2007.

Resolution CTA EB NO. 2154 (CTA AC NO. 197) SO ORDERED. ~ . .4J.,_ .-tl t.____ MA. BELEN M. RINGPIS-LIBAN Associate Justice WE CONCUR: (I rez!erate my Concuffing Opinion) ROMAN G. DEL ROSARIO Presiding Justice <;k-~c~~ ~ ERL~P.UY Associate Justice Jlt:\NITo c. CASTANEDAtJR. Associate Justice ~~7-~ ~ CATHERINE T. MANAHAN JEAN lVllHVf!. ~1CORRO-VILLENA Associate Justice