PEOPLE OF THE PHILIPPINES v. NICHOLSON C. SANTOS, JOSEPHINE CHEN c/o GULFOSS INTERNATIONAL CORPORATION Unit 1204 12F World Trade Exchange Building, 215 Juan Luna St., Binondo, Manila 1016

.- REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Second Division PEOPLE OF THE PHILIPPINES, CTA Crim. Case No. 0-1225 Plaintiff, (NPS Docket No. XV-07-INV- 24H-03497) -versus- For: VIOLATION OF SECTIONS 254 AND 255 IN RELATION TO SECTIONS 253(d) & 256 OF THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED NICHOLSON C. SANTOS Members: JOSEPHINE CHEN RINGPIS-LIBAN, Chairperson, c/o GULFOSS INTERNATIONAL MODESTO-SAN PEDRO, and CORPORATION FERRER-FLORES, JJ Unit 1204 12F World Trade Exchange Building, 215 Juan Luna St., Binondo, Promulgated: Manila 1006, ,,. X -----------------------------A--c-c-u--s-e-d--.------------------------------------+----------- x RESOLUTION Before the Court is plaintiffs Motion for Reconsideration with Entry ofAppearance (Re: Resolution dated February 20, 2025), filed on September 19, 2025, assailing this Court's dismissal of the instant case through Our Resolution, dated February 20, 2025. The Motion was filed late. The assailed Resolution has attained finality. Records show that the Bureau of Internal Revenue ("BIR"), which filed the instant Motion as deputized prosecution, received the assailed Resolution as early as on February 27, 2025. 1 Plaintiff does not controvert this, stating that the Litigation Division of its National Office received the Motion on February 7, 2025. This seems to be a typographical error, as February 7, 2025 predates the Resolution's promulgation, so the Court interprets this as simply agreeing with recorded date of receipt, February 27, 2025. Notice of Resolution, Rollo, p. 97.

.- RESOLUTION CTA Crim. Case No. 0-1225 Page 2of2 That the National Office only forwarded the assailed Resolution to Revenue Region No. 6, Manila, on September 5, 2025 is of no moment. Nothing submitted by plaintiff suggests that only the Legal Division of Revenue Region No.6, Manila, and not the Litigation Division ofthe National Office, was deputized as special prosecution. Receipt of the assailed Resolution by the National Office was thus receipt by plaintiff. In any event, accused should not be made to suffer for the BIR' s negligence in timely forwarding Court issuances to its own offices and divisions. Allowing such would give the BIR the power to delay proceedings and ignore prescriptive periods by simply halting its internal routing of received Court issuances. Considering that plaintiff received the assailed Resolution on February 27, 2025, it had until March 14, 2025 within which to file a Motion for Reconsideration, under Rule 15, Section 1 of the Revised Rules of the Court o.fTax Appeals. It filed no such Motion. Its statutory right to do so was thus forfeited, and the assailed Resolution can no longer be challenged. Furthermore, the City Prosecutor's Office of Manila, which remained as members of the prosecution despite the BIR's presence as special prosecutors, received the assailed Resolution on March 4, 2025.2 If We ignore the BIR's February 27, 2025 receipt of the Resolution, despite having no reason to do so, plaintiff would still only have until March 19, 2025 within which to file its Motion. Since it did not, the Resolution attained finality. The Motion thus cannot be granted. ACCORDINGLY, the instant Motion for Reconsideration with Entry ofAppearance (Re: Resolution dated February 20, 2025), filed on September 19, 2025, is hereby DENIED for being filed late. The assailed Resolution, dated February 20, 2025, is hereby AFFIRMED. SO ORDEREDi1. ~- ~ ....,....__ MA. BELEN M. RINGPIS-LIBAN On leave CORAZON G. FERRER-FLORES Associate Justice !d.