COMMISSIONER OF INTERNAL REVENUE v. WILL TEAM PH, INC.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC COMMISSIONER OF INTERNAL CTA EB NO. 2884 REVENUE, (CTA Case No . 10154) Petitioner, Present: - versus - RINGPIS-LIBAN, Acting P.J ., MANAHAN, BACORRO-VILLENA, MODESTO-SAN PEDRO, REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and ANGELES, JJ. Promulgated: WILL TEAM PH, INC. , Respondent. X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X RESOLUTION CUI-DAVID, J.: Before the Court En B ane is p etition er's Motion for Reconsideration (Re: Decision promulgated 16 July 2025), 1 filed on August 6 , 2025 , assailing the D ecision2 promulgated on July 16, 2025 ("assailed Decision'), the dispositive portion of which reads: Assailed Decision: WHEREFORE, premises considered, the Petition for Review filed by the Commissioner of Internal Revenue is DENIED, for lack of m erit. The assailed Decision dated October 5, 2023 a nd Resolution dated February 22, 2024, both issued by the Special First Division in CTA Case No. 10154 are AFFIRMED. SO ORDERED. En Bane (EB) Docket. pp. 248- 258. !d. at 228- 247.

RESOLUTION CTA EB No. 2884 (CTA Case No. 10154) Commissioner of Internal Revenue v. Will Team Ph, Inc. X---------------------------------------------------------------------X The assailed Decision sustained the ruling of the Court in Division ordering the cancellation and setting aside of the: 1. Formal Letter of Demand (FLD) dated September 11, 20 18; 2. Final Decision on Disputed Assessment (FDDA) dated July 11, 2019;and 3. Warrant of Distraint and/or Levy (WDL) dated November 18, 2019, all issued against respondent for taxable year 2016. In seeking reconsideration, petitioner raises the sole ground: WHETHER OR NOT THE HONORABLE COURT ERRED WHEN IT CANCELLED THE FLD, FDDA, AND THE WDL ON THE GROUND THAT THE SAME ARE VOID AND WITHOUT ANY LEGAL SIGNIFICANCE FOR RESPONDENT'S (sic) WANTON DISREGARD OF THE DUE PROCESS REQUIREMENTS OF SECTION 228 OF THE NIRC OF 1997, AS AMENDED, RR NO. 12-99, AS AMENDED, AND THE AVON CASE. By way of Comment/ Opposition (To the Motion for Reconsideration Re: Decision promulgated 16 July 2025)3 filed on August 20, 2025, respondent interposed the following counter-arguments: I. THE HONORABLE COURT DID NOT ERR IN HOLDING THAT THE TAX ASSESSMENTS ARE VOID DUE TO PETITIONER'S VIOLATION OF RESPONDENT'S RIGHT TO DUE PROCESS. II. THE AVON DOCTRINE APPLIED BY THIS HONORABLE COURT IS NOT JUDICIAL LEGISLATION, BUT BINDING JURISPRUDENCE WHICH FORMS PART OF THE LAW OF THE LAND. III. PETITIONER'S MOTION FOR RECONSIDERATION IS A MERE PRO-FORMA MOTION. After carefully reviewing the arguments in the Motion for Reconsideration and the counter-arguments of respondent, the Court En Bane finds no cogent reason to deviate from its ruling in the assailed Decision dated July 16, 2025. The Motion for Reconsideration has not raised any new or substantial ground that would justify a departure from the previous conclusion and finding of the Court En Bane. All the Issues !d. at 264-284.

RESOLUTION CTA EB No. 2884 (CTA Case No. 10154) Commissioner of Internal Revenue v. Will Team Ph, Inc. X---------------------------------------------------------------------X and arguments raised have already been passed upon, amply discussed, and considered by the Court En Bane in the assailed Decision. As the Supreme Court aptly stated m Social Justice Society (SJS) Officers v. Lim: 4 The filing of a motion for reconsideration, authorized by Rule 52 of the Rules of Court, does not impose on the Court the obligation to deal individually and specifically with the grounds relied upon therefor, in much the same way that the Court does in its judgment or final order as regards the issues raised and submitted for decision. This would be a useless formality or ritual invariably involving merely a reiteration of the reasons already set forth in the judgment or final order for rejecting the arguments advanced by the movant; and it would be a needless act, too, with respect to issues raised for the first time, these being, as above stated, deemed waived because not asserted at the first opportunity. It suffices for the Court to deal generally and summarily with the motion for reconsideration, and merely state a legal ground for its denial (Sec. 14, Art. VIII, Constitution); i.e., the motion contains merely a reiteration or rehash of arguments already submitted to and pronounced without merit by the Court in its judgment, or the basic issues have already been passed upon, or the motion discloses no substantial argument or cogent reason to warrant reconsideration or modification of the judgment or final order; or the arguments in the motion are too unsubstantial to require consideration, etc. (Emphasis supplied) Guided by the foregoing principle, the Court En Bane finds no justification to disturb its ruling. Accordingly, the assailed Decision stands. WHEREFORE, premises considered, petitioner's Motion for Reconsideration (Re: Decision promulgated 16 July 2025) is hereby DENIED, for lack of merit. SO ORDERED. ~ LANEE S. CUI-DAVID Associate Justice G.R. !\o. 187836 & 187916. March 10.:?:015 p>er J. P~ro. En BcmcJ.

RESOLUTION CTA EBNo. 2884 (CTA Case No. 10154) Commissioner of Internal Revenue v. Will Team Ph, Inc. X---------------------------------------------------------------------X WE CONCUR: ~.~ "1'- MA. BELEN M. RlNGPIS-LIBAN Associate Justice c~� -~ CATHERlJ T. MANAHAN Associate Justice r ' JEANMA . BACORRO-VILLENA ciate Justice ON OFFICIAL BUSINESS MARlA ROWENA MODESTO-SAN PEDRO Associate Justice ~ ~ F 4.._ - r41~o~t> MARIAN Iffl. REYkS-FA:TARDO Associate Justice C~ ~�.tfER~oRES Associate Justi HENRY iJ?ANGELES Associate Justice