RED RIBBON BAKESHOP, INC. v. BRANCH 196-REGIONAL TRIAL COURT OF PARA?AQUE CITY, THE CITY OF PARA?AQUE AND DR. ANTHONY L. PULMANO IN HIS CAPACITY AS CITY TREASURER

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Second Division RED RIBBON BAKESHOP, CTA SCA CASE NO. 0025 INC., Petitioner, Members: -versus- RINGPIS-LIBAN, Chairperson, MODESTO-SAN PEDRO, and BRANCH 196- REGIONAL FERRER-FLORES, JJ TRIAL COURT OF PARANAQUE AND DR. ANTHONY L. PULMANO IN Promulgated: HIS CAPACITY AS CITY TREASURER, Si'____ Respondents. ___________________________1_~_tc"_.::_~~!~----- x X ---------------------------------------------------------- RESOLUTION For the Court's resolution is petitioner's Motion for Reconsideration (Re: Resolution dated October 8, 2024), filed on December 6, 2024. Petitioner assails this Court's dismissal of its Petition for Certiorari through a Resolution, 1 dated October 8, 2024 ("assailed Resolution"). It argues that (1) the Rules on Expedited Procedures in First Level Courts ("Rules on Expedited Procedures") is clear that the judgment of the Regional Trial Court ("RTC") on appeal shall be final, leaving no room for interpretation; (2) the Revised Rules ofthe Court ofTax Appeals, as amended ("RRCTA"), is silent on where to file petitions for certiorari; and (3) the Supreme Court had dismissed work on August 28, 2024, so petitioner had until August 29, 2024, within which to file its petition. While petitioner's third point is well taken, the Motion ultimately lacks merit. First, Our dismissal of the case at bar despite the Rules on Expedited Procedures stating that the judgments of the RTC on appeals are final did not involve an interpretation of said rule. To reiterate, We said that the seeming contradiction between the Rules on Expedited Procedures and the RRCTA must be resolved in favor of the latter. In other words, the issue does not involve interpreting a single rule-it involves determining which of two Rollo, pages 147-148.

RESOLUTION CTA SCA CASE NO. 0025 Page 2 of3 contradictory rules must prevail. As such, the principle that a clear and unambiguous law leaves no room for interpretation, that the Courts must simply apply rather than interpret or circumvent, is irrelevant here. Even if We were to agree that petitioner's interpretation is the only valid way of reading the Rules on Expedited Procedure, We would still have to dismiss this � case. The above is so because, to repeat, Section 7(a)(3) of Republic Act ("RA" ) No. 1125, as amended, and Rule 4, Section 2(a)(c) of the RRCTA clearly and unambiguously establish the Court of Tax Appeals ("CTA") En Bane's jurisdiction over appeals from rulings of the RTC in the exercise of the latter's appellate jurisdiction. And given that RA No. 1125, as amended, and the RRCTA are (1) special laws that govern a specific subset of cases that could be heard before the RTC; and (2) are the laws particular to this Court, We have to resolve the contradiction in favor of RA No. 1125, as amended, and the RRCTA. Hence, Our finding that We lack jurisdiction over this case. Indeed, agreeing with petitioner on this point would completely negate the two aforementioned provisions. Section 7(a)(3) of Republic Act ("RA") No. 1125, as amended, and Rule 4, Section 2(a) (c) ofthe RRCTA would "be rendered ineffectual, as the specific remedy provided by those two Sections would be barred. On the other hand, deeming said laws to prevail over the Rules ofExpedited Procedure in this specific context would not negate said Rules. The finality of the RTC's judgments on appeal would still stand in general. The availability of appeals from such judgments in cases involving . local taxes specifically would simply be a special exemption to the general rule . In sum, as petitioner' s first argument merely defends an interpretation of the Rules on Expedited Procedure but does not show why it should prevail over both RA No. 1125, as amended, and the RRCTA, it misses the point entirely and raises no substantial challenge to Our ruling. The argument must thus be rejected. Consequently, petitioner' s second argument must fail as well. Even if the RRCTA is silent on petitions for certiorari raised from the RTC, such silence is irrelevant to petitioner's case. Again, an appeal to the CTA En Bane was still available to petitioner, under RA No. 1125, as amended, and the RRCTA . It thus should not have filed its Petition as one for certiorari in the first place. Consequently, even if We were to agree that Petitions from Certiorari from rulings of the RTC should be filed before the Court in Division, We would still dismiss this case as a regular appeal was still available to it.

RESOL UT I O N CTA SCA CASE NO. 0025 Page 3 of3 Given the foregoing, even though petitioner is correct on its third point, and the relevant prescriptive period ended on August 29, 2024, it is incorrect on its other two points, having failed to directly address the reasons for the dismissal of this case. We thus see no reason to set aside the assailed Resolution. ACCORDINGLY, the instant Motion for Reconsideration (Re: Resolution dated October 8, 2024), filed on December 6, 2024, is hereby DENIED for lack of merit. SO ORDERED. L.~ ~ '--- MA. BELEN M. RINGPIS-LIBAN Associate Justice co~ [~Q1fus Associate Justice