BELLE BAY CITY CORPORATION v. CENTRAL BOARD OF ASSESSMENT APPEALS, CITY ASSESSOR AND CITY TREASURER OF PARA?AQUE CITY

Republic of th e Philippines COURT OFTAX APPEALS Quezo n City En Bane BELLE BAY CITY CORPORATION, CTA EB Case No. 1038 Pe t i t i o n e r, (CBAA Case Nos. L-51, L-51A a nd L-58) Present: DEL ROSARIO, Pj, CASTANEDA, JR., - versus - BAUTISTA, UY, CASANOVA, FABON-VICTORINO, MINDARO-GRULLA, COTANGCO-MANALASTAS, and CENTRAL BOARD OF ASSESSMENT RINGPIS-LIBAN, J.L APPEALS, CITY ASSESSOR AND CITY TREASURER OF PARANAQUE Promulgated: CITY, x- --- - - --- - - - - - - -- - -- ~-e_s~-~~~~~~~�- - - - ~-~~}~4-q_.-~ : - --- -- ----x RESOLUTION CASANOVA,L_: Submitted for conside ration is petitioner's "MOTION FOR RECONSIDERATION (OF DECISION DATED 2 SEPTEMBER 2014)" fil ed on October 9, 2014 without respondents' comment per CTA Records Verification dated Ja nuary 22, 2015. The dispositive portion of the said Decision reads as fo llows: "WHEREFORE, the insta nt Petition for Review En Bane is hereby DENIED for lack of merit. The assailed Decisions dated July 30, 2012 and Orders dated Februa ry 26, 201 3 of the Central Board of Assessme nt Appeals are both AFFIRMED in toto.d/

RESOLUTION CTA EB Case No. 10 38 (CBAA Case Nos. L-51, L-51A and L-58) Page 2 of3 SO ORDERED." In its Motion, petitioner raises as an assignment of error the Court En Bane's ruling that the subject assessments have become final and unappealable. Petitioner asserts that the said assessments are null and void for having violated Department of Finance Local Assessment Regulation No. 1-92 and Parafiaque City Ordinance No. 96-16. We find no merit in petitioner's Motion for Reconsideration. The arguments/discussions proffered by petitioner in its Motion for Reconsideration have already been thoroughly discussed in the assailed En Bane Decision. What the instant Motion for Reconsideration seeks is for the Court En Bane to view and appreciate the facts and evidence in its own perspective, which unfortunately had already been considered and passed upon. As to petitioner's final note in its Motion, that: "[p]etitioner would like to stress that it had already lost a part of its property when it paid the amount assessed by respondent City Assessor - despite the uncontroverted fact that it was not based on correct valuation. This Honorable Court should, at the very least, allow the determination on whether respondents complied with rules on assessment as mandated by the DOFLAR 1-92 and CPO 96-16. This Honorable Court, like any other court, must avoid technicalities that often leads to injustice and deprivation ofrights." The Supreme Court on numerous occasions had the opportunity to rule that courts and judges should be allowed to synthesize and to simplify their decisions considering that at present, courts are harassed by crowded dockets and time constraints.1 In making their indictment that a court's decision fails to express clearly and distinctly the facts and the law on which it is based, petitioners should not mistake brevity for levity. 2a;l.,.. 1 joaquin G. Chung, et al. vs. jack Daniel Mo ndragon, (deceased), et al., G.R. No. 179754, November 21, 2012; Also, see People of the Philippines vs. Delia Sadiosa, G.R. No. 107084, May 15, 1998; Bernabe vs. Geraldez, L-39721, July 15, 1975; jose, et al. vs. Santos, et al., L- 255 10, October 30, 1970 z Ibid.

RESOLUTION CTA EB Case No. 1038 (CBAA Case Nos. L-51, L-51A and L-58) Page 3 of3 All told, We find no cogent justification to disturb the findings and conclusions spelled out in the September 2, 2014 En Bane Decision. WHEREFORE, petitioner's Motion for Reconsideration (of Decision dated 2 September 2014) is hereby DENIED for lack of merit. SO ORDERED. CAES~SANOVA WE CONCUR: Associate Justice Presiding Justice a. ~-,;, c .~~. Cl . Assoc� (tfANITO C. CASTANEDAfiR. Associate Justice ER~. UY ~/'~~ Associate Justice AMELIA R. COTANGCO-MANALASTAS Associate Justice (On Lt:aV~i CIELITO N. MINDARO-GRULLA Associate Justice Qr..t,. ~ ~� J-_ MA. BELEN M. RINGPIS-LIBAN Associate Justice