PEOPLE OF THE PHILIPPINES v. INFINITY DYNAMIC SYSTEMS AND SOLUTIONS, INC. (28th Floor The Enterprise Centre Tower II, Ayala Avenue, Makati City), JOSE EMMANUEL B. ESCARO (8 Sateen Lane, Ametta Place, San Miguel and/or c/o Infinity Dynamic Systems and Solutions, Inc. 28th Floor The Enterprise Centre Tower II, Ayala Avenue, Makati City) SHERYL E. SERRANO (79 Flamingo Street, St. Francis Subdivision, Meycauayan, Bulacan and/or Infinity Dynamic Systems and Solutions, Inc. 28th Floor The Enterprise Centre Tower II, Ayala Avenue, Makati City)(All At-Large)

CTA Fom1 No. 8 (For DCC) llllllllllll ll llllllll llll lllllllllll lll lllllllllll llll ll lllllllllll 23-000 138� 0021 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA CRJM. CASE NO. 0-1035 PEOPLE OF THE PHILIPPINES, Plaintiff, -versus- MELAND G. DILODILO, NOTICE OF RESOLUTION Global Die Cast & Forging Inc. No. 6001-R Tatalon St. , Ugong Valenzuela City, Accu sed. To: CITY PROS ECUTOR FERDINAND U. VALBUENA ASST. CITY PROSECUTOR J AC K A. MENDAROS Departm.:nt ofJustice Office of th.: City Prosl.!cutor 3rd Floor, Jud icial Compkx Building I Oth A venue. Caloocan City ATTY. LORNA SB. CRUZ ATTY. LEI ADRIAN V. GAPOY ATTY. ARLYN T. CORRO ATTY. AYLEEN B. ALMIRA Bureau ofTntcrnal Revenue- Revenue Region No. 5 9/F, BI R Building, Legal Di vision - 12 G. Concepcion Street. Brgy. 134 Caloocan City ATTY. MARIA ASUNCION D. PABLICO 136 Macabagdal Street corner gth Street Brgy. 92, East Grace Park Caloocan City MR. MELAND G. DILODILO o. 136C Macabagda l Street, Grace Park Caloocan City GREETINGS: You are hereby notified by these presents that on January 12, 2024, a R esolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, January 15, 2024. Page I of I

,' REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION PEOPLE OF THE CTA Crim. Case No. 0-1035 PHILIPPINES, For: Violation of Sec. 255 in rel. to Sec. Plaintiff, 253(d) of the NIRC -versus- Members: DEL ROSARIO, P.J. , Chairperson, BACORRO-VILLENA, and CUI-DAVID, JJ. MELAND G. DILODILO, Promulgated: Global Die Cast & Forging Inc. No 600 1-R Tatalon St., Ugong Valenzuela City Accused. For the Court's Resolution is plaintiff's Omnibus Motion for Reconsideration (with Motion to Admit/with Leave of Court) and Entry of Appearance filed on October 24, 2023, with accused's Opposition (to Plaintiffs Omnibus Motion for Reconsideration with Motion to Admit/with Leave of Court and Entry of Appearance) filed on November 3, 2023. Plaintiff moves that the Court's Resolution dated August 11, 2023, which dismisses the instant case on the ground of prescription, be reversed and set aside. We deny. First, the instant Omnibus Motion for Reconsideration is filed out of time. Records reveal that the dismissal has already attained finality with the issuance of the Entry ofJudgment on October 19,2023, pursuant to Section 6, Rule 14 ofthe Revised

RESOLUTION CTA Crim Case No. 0-1035 People of the Philippines vs. Meland G. Dilodilo x-- ----------------------------------------------------------------------------------------x Rules of the Court of Tax Appeals ("RRCTA") 1 in relation to Section 8, Rule 120 of the Revised Rules of Criminal Procedure.2 Records further reveal that plaintiff received the Resolution dated August 11, 2023, on August 18, 2023. Plaintiff filed its Omnibus Motion for Reconsideration only 66 days after or on October 23, 2023, long after the dismissal had attained finality. Second, plaintiff cites Panaguiton, Jr. v. Department of Justice, 3 People v. Pangilinan,4 and People v. Bautista. 5 A perusal of plaintiff's citations discloses that, while they discuss the prescription of crimes, these cases do not specifically discuss the prescription of crimes under the NIRC of 1997, as amended, which is governed by a different provision of law. The applicable and controlling case is Emilio E. Lim, Sr. and Antonia Sun Lim vs. Court of Appeals ("Lim"}, 6 which discussed the prescription of crimes specifically in relation to Section 354 of the 1939 Tax Code, which was reproduced 1n Section 281 of the NIRC of 1997, as amended. To reiterate, the Supreme Court enunciated in Lim that tax criminal cases are imprescriptible. However, violations shall nevertheless prescribe if more than five (5} years have lapsed from the time of the commission of the offense if known, and as applicable in this case, i.e., the date of finality of the Final Assessment Notice (FAN}/Formal Letter of Demand (FLD}, up to the date of filing of the Information before the Court. Accordingly, plaintiff had five (5} years counted from June 4, 2014, or until June 4, 2019, to file the Information before the Court. The Information, dated March 17, 2021, was filed only on April 13, 2023.7 We maintain our Resolution that the filing of the Information is already time-barred. 1 SECTION 6. Entry ofJudgment and Final Reso lution. - If no appeal or motion fo r reconsideration or new trial is fi led within the time provided in these Rules, the Clerk of Court shall forthwith enter the judgment or final resolution in the book of judg ment. The date when the judgment or final resolution becomes executory shall be deemed the date of its entry. The entry shall contain the d ispositive part of the judgment or final resolution and shall be signed by the Clerk of Court, with a certification that such j udgment or resolution has become final and executory. 2 SECTION 8. Entry of Judgment.- After a judgment has become fin al, it shall be entered in accordance with Rule 36. 3 G.R. No. 16757 1. Novemher 25. 2001!. 592 PH IL 21!6-298. 4 G.R. No. 152662, June 13, 20 12, 687 PHIL 95- 106. 5 G.R. No. 16864 1, April27, 2007, 550 PHIL 835-84 1. 6 G.R. Nos. L-48 134-37, October 18, 1990, 268 PHIL 680-692. 7 Docket, pp. 5-6.

RESOLUTION CTA Crim Case No . 0-1035 People of the Philippines vs. Meland G. Dilodilo x------------------------------------------------------------------------------------------x WHEREFORE, plaintiff's Omnibus Motion for Reconsideration (with Motion to Admit/ with Leave of Court) is DENIED. Plaintiff's counsel Entry ofAppearance is NOTED. SO ORDERED. Presiding Justice JEAN MA Ju~IAAdil~ LAN~vbUI-DAVID Associate Justice