TRICOR MANAGEMENT & DEVELOPMENT CORPORATION Represented by MELANIE R. GERASTA v. CEBU CITY GOVERNMENT and OFFICE OF THE CITY TREASURER, represented by MARE VAE F. REYES, City Treasurer of Cebu City

CTA Form No. 8 (For DCC) 1111111111111111 111111 1111111111 111111111111111 111111111111111111111111111111111 23-000324-0017 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA AC NO. 299 TRICOR MANAGEMENT & DEVELOPMENT CORPORATION Represented by MELANIE R. GERASTA, Petitioner, -versus - NOTICE OF RESOLUTION CEBU CITY GOVERNMENT AND OFFICE OF THE CITY TREASURER, represented by MARE VAE F. REYES, City Treasurer of Cebu City, Respondent. To: ATTY. AARON LEE SOLON YAP (Counselfor the Petitioner) Concession Space No. 3 The Regency Crest, Maria Luisa Rd. Banilad, Cebu City 6000 RON. MICHAEL LOPEZ RAMA City Mayor Cebu City Government Ground Floor, Executive Building Cebu City Hall, M.C. Briones Street Cebu City ATTY. EUGENE C. ORBITA Head, Cebu City Legal Office Ground Floor, Legislative Building Cebu City Hall, M.C. Briones Street Cebu City MS. MARE VAE F. REYES City Treasurer Cebu City Government 2nd Floor, Cebu City Finance Center Building M .C. Briones Street, Cebu City ATTY. CARLO VINCENT E. GIMENA (Counsel for the Respondents) Ground Floor, New Legislative Building Cebu City Hall, Jose Rizal Street, Cebu City HON. GRACE M. VELOSO-FERNANDEZ Presiding Judge THRU: ATTY. NANETTE C. GABUTAN Branch Clerk of Court- OIC Regional Trial Court 7th Judicial Region Branch 19, Cebu City Port Service Road, North Reclamation Area Cebu City Page 1 of2

GREETINGS: You are hereby notified by these presents that on February 5, 2025, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, February 10, 2025. \ Atty. Maria Jo~Chan-Te Executive C-l~urt II Page 2 of2

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION TRICOR MANAGEMENT & CTA AC NO. 299 DEVELOPMENT CORPORATION Represented by MELANIE R. Members: GERASTA, DEL ROSARIO, P.J., Chairperson, Petitioner-Appellant, BACORRO-VILLENA, and CUI-DAVID, JJ. -versus- CEBU CITY GOVERNMENT and Promulgated: OFFICE OF THE CITY FEB 05 2025 . 1/;:~opM TREASURER, represented by MARE VAE F. REYES, City Treasurer of Cebu City, Respondents-Appellees. ){- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - -){ RESOLUTION CUI-DAVID, J.: On August 22, 2024, the Court promulgated a Decision, I the dispositive portion of which reads: WHEREFORE, premises considered, the in' stant Petition for Review is DENIED, for lack of merit. Accordingly, the Orders dated March 7, 2023 and June 19, 2023, both issued by the Regional Trial Court of Cebu City, Branch 19 in Civil Case No. R-CEB-22-06407-CV, are hereby AFFIRMED . SO ORDERED. The aforesaid Decision sustained the ruling of the court a quo, ordering the dismissal of the Complaint filed by petitioner on jurisdictional grounds. 1 Docket, pp. 791- 808.

RESOLUTION CTA AC No. 299 Tricor Management & Development Corporation v. Cebu City Government and Office of the City Treasurer, represented by Mare Vae F. Reyes, City Treasurer of Cebu City X------------------------------------------------------------------------------------X Unyielding, petitioner personally filed the instant Motion for Reconsideration (Motion) on October 10, 2024, and subsequently submitted it via electronic mail (e-mail) on November 13, 2024. The Motion is anchored on the following grounds: I. The Court May Have Misapprehended the Nature of the Case, Which Properly Falls Within the Original Jurisdiction of the Regional Trial Court. II. The Power to Impose Business Taxes is Beyond Pecuniary Estimation. III. The Nature of the Case Necessitates the Expertise and Authority of the RTC. IV. Public Policy and Substantial Justice Demand the 'RTC's Intervention in Tax Assessment Disputes. In their Comment and Vehement Opposition to Petitioner's Motion for Reconsideration dated October 9, 2024, filed through registered mail and e-mail on October 24, 2024, respondents submit the following reasons and grounds for the denial of the Motion: I. THE HONORABLE COURT HAS CORRECTLY RULED THAT THE CASE SUBJECT OF THE INSTANT PETITION FOR REVIEW IS CAPABLE OF PECUNIARY ESTIMATION AND THAT THE REGIONAL TRIAL COURT HAD NO JURISDICTION OVER PETITIONER'S COMPLAINT; II. PETITIONER'S RESERVATIONS AS TO THE COMPETENCY OF THE FIRST LEVEL COURTS TO HEAR AND TRY ITS COMPLAINT . ARE UNFOUNDED AND ARE BORDERLINE IN CONTEMPT OF COURT; Ill. PETITIONER'S INVOCATION OF THE CASES OF THE CITY TREASURER OF MAKATI CITY V. MICHIGAN HOLDINGS, INC. AND TY VS. TRAMPE IS MISPLACED AND INCORRECT; IV. THE DISMISSAL OF THE COMPLAINT SUBJECT OF THE INSTANT PETITION FOR REVIEW WAS PROPER AND WARRANTED CONSIDERING THAT:

RESOLUTION CTA AC No. 299 Tricor Management & Development Corporation v. Cebu City Government and Office of the City Treasurer, represented by Mare Vae F. Reyes, City Treasurer of Cebu City x------------------------------------------------------------------------------------x A. PETITIONER HAS NO LEGAL CAPACITY TO SUE; B. THE COMPLAINT HAS BEEN BARRED BY STATUTE OF LIMITATIONS BECAUSE THE LETTER OF ASSESSMENT (FINAL DEMAND) DATED OCTOBER 5, 2022 HAD ALREADY BECOME FINAL AND EXECUTORY DUE TO PETITIONER'S FAILURE TO FILE PROTEST WITHIN THE REGLEMENTARY OR PRESCRIPTIVE PERIOD PROVIDED FOR UNDER SECTION 195 OF RA NO. 7160; C. THE VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING APPENDED TO THE COMPLAINT IS FATALLY DEFECTIVE; AND D. THE LETTERS OF ASSESSMENT DATED JUNE 30, 2022 AND OCTOBER 5, 2022 WERE PROPERLY MADE. After carefully reviewing the grounds raised in the Motion for Reconsideration and the arguments set forth by petitioner, the Court finds no cogent reason to deviate from its ruling in the assailed Decision of August 22, 2024. The contentions presented in the Motion are merely reiterations or amplifications of petitioner's previous arguments, all of which have been duly considered and thoroughly discussed in the Decision under reconsideration. To repeat the discussion from the assailed Decision would serve no purpose other than to result in redundancy. Accordingly, the Court stands by its original ruling. WHEREFORE, petitioner's Motion for Reconsideration filed on October 10, 2024 is DENIED, for lack of merit. SO ORDERED. ~ti11K_ LANEE S. CUI-DAVID Associate Justice

RESOLUTION CTA AC No. 299 Tricor Management & Development Corporation v. Cebu City Government and Office of the City Treasurer, represented by Mare Vae F. Reyes, City Treasurer of Cebu City X------------------------------------------------------------------------------------X WE CONCUR: Presiding Justice JEAN MA ciate Justice