COMMISSIONER OF INTERNAL REVENUE v. PETRON CORPORATION

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 2894 REVENUE, (CTA Case No. 9947) Petitioner, Present: RINGPIS-LIBAN, Acting P.J, MANAHAN, BACORRO-VILLENA, MODESTO-SAN PEDRO, -versus- REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and ANGELES,JJ Promulgated: PETRON CORPORATION, NOV 2 4 2~) Respondent. ~,- X .~ . _c __ __ , X ---------------------------------------------------------------------------------------- ~. RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration (Re: Decision promulgated on OJ August 2025), filed on August 15, 2025, with respondent's Opposition (To: Motion for Reconsideration dated 12 August 2025), filed via registered mail on August 28, 2025, assailing this Court En Bane's Decision, dated August 1, 2025. The Motion is bereft of merit. In it, petitioner merely quotes a previous ruling1 of this Court of Tax Appeals ("CTA") En Bane which ruled in his favor. He does not, however, explain why this ruling should prevail over the Supreme Court ruling used as the basis of the Assailed Decision, Petron Corporation v. Commissioner ofInternal Revenue.2 He does not even directly f address said ruling, which was promulgated more recently than the CTA Peu�on Corporation v. Commissioner ofInternal Revenue, CTA EB No. 2425, June 28, 2022. G.R. No. 255961 , March 20, 2023 .

RESOLlTIO' CT A F.B NO. 289-t {CTA Case :"Jo. 99-J.7J Page 2 of2 ruling that he cites. We are consequently not convinced that alkylate is, in fact, subject to excise tax. Our ruling in the assailed Decision stands. ACCORDINGLY, the Motion for Reconsideration {Re: Decision promulgated on OJ August 2025), filed on August 15, 2025, is hereby DENIED for lack of merit. The Decision, dated August I, 2025, is AFFIRMED. SO ORDERED. MARlAR WE CONCUR: u .. ~- 7 ..__ MA. BELEN M. RINGPIS-LIBAN Associate Justice Inhibited. CATHERINE T. MANAHAN Assoc.-iate Justice ~ ~t~-t=f4�~ MARIAN IV~ F. RE�kS-FAiARDO Associate Justice lhtiMthif LANtr;~~UI-~). VID Associate Justice c~ t. ~s:-'2:~~ Associate Justice HENRY /./!;GELES Associate Justice