DMCI-PDI HOTELS INC. v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Third Division DMCI-PDI HOTELS, INC., CTA CASE N0.11352 Petitioner, Members: MODESTO-SAN PEDRO, Chairperson, -versus- FERRER-FLORES, and CENTENO-DIJAMCO, JJ COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. SEP 2 5 2026 X ----------------------------------------------------------~----j_-;_fi__e_~-~-'-------------------------- X RESOLUTION For the Court' s resolution is petitioner' s Motion to Withdraw Petition for Review, filed on June 3, 2026, with respondent's Comment, filed on June 22, 2026. In brief, petitioner seeks to withdraw the instant Petition as its offer of compromise was accepted by respondent, as shown by the attached Certificate of A vai lment. As per Commissioner of Internal Revenue v. Nippon Express (Phils.) Corporation, 1 an appeal before this Court may be withdrawn ( 1) at any time before the case is submitted for resolution; or (2) even after such submission and the filing of the appellee ' s brief or equivalent pleading, with the discretion of the Court. Considering that this case has not yet been submitted for decision, the Court deems it appropriate to grant the withdrawal. That said, the withdrawal of an appeal results in the assailed decision becoming final and executory.2 Consequently, the various issuances petitioner previously sought to annul shall become final and executory, the compromise apparently reached by the parties notwithstanding. G. R. No. 2 12920, Seprember 16,201 5. Central Luzon Drug v. Commissioner of Internal Revenue, G.R. No. 181 37 1, March 2, 20 II .

RESO L T ION CT A CASE NO. 11352 Page 2 of2 ACCORDINGLY, petitioner' s Motion to Withdraw Petition, filed on June 3, 2026, is hereby GRANTED. The instant Petition for Review is deemed WITHDRAWN, and this case is now CLOSED and TERMINATED. SO ORDERED. MARIA DEBBIEJE I. CENTENO-DIJAMCO